This week, the CFPB issued its first Semi-Annual Report to the President and Congress covering its activities through December 31, 2011. The report contains no real surprises, including that the CFPB expects the pace of its work to “intensify” over the next six months. Nevertheless, its description of the CFPB’s structure and recounting of the CFPB’s activities make it worthwhile reading for anyone needing a refresher on what the CFPB has been doing since its launch on July 21, 2011. In addition, a few items deserve mention.
First, the CFPB reports that it now has more than 750 employees across the country, 230 of whom transferred from other federal agencies. It also reports that it spent approximately $123.3 million in fiscal year 2011, including $68.7 million in contract and support services, $48.4 million in salary and benefits and $6.2 million in other expenses.
Second, the CFPB’s list of “rules, orders, and other initiatives” it has planned for the next six month does not include any unexpected items, with much of the list consisting of mortgage loan-related items that implement Dodd-Frank Title XIV. Noticeably absent from the list is any mention of Section 1028 of Dodd-Frank which requires the CFPB to conduct a study of pre-dispute arbitration provisions in consumer financial services contracts and about which we shared some thoughts in an earlier blog post.
Third, Dodd-Frank requires the CFPB to include in its reports ” a discussion of the significant problems faced by consumers in shopping for or obtaining consumer products or services.” Responding to that requirement, the report contains a section titled “Shopping Challenges” which the CFPB describes as “a set of preliminary observations about opportunities and challenges that consumers face when shopping for mortgages, credit cards, and student loans.” For its first report, the CFPB focuses on the ability of consumer’s to shop for these products based on price terms (e.g. interest rate and fees) and indicates future reports may consider “fair lending issues that may limit some consumers’ ability to shop.” It seems likely that the concerns the CFPB identifies in these reports will find their way into future CFPB rulemaking and other actions.