The CFPB has issued an updated report on its strategic plan, budget, and performance plan. The report, which mostly reassembles information contained in other CFPB reports, discusses the CFPB’s progress in meeting the strategic goals set forth in its FY 2013-FY 2017 strategic plan and provides budget projections and other metrics for FYs 2014 and 2015.
The CFPB’s estimated budget for FYs 2014 and 2015 is, respectively, $569.8 million and $583.4 million. (The FY 2013 budget was $538.7 million.) The budget breakdown by program shows that the programs with the most significant increases in funding in FYs 2014 and 2015 as compared with FY 2013 are Consumer Response Operations (increasing from $39.5 million in FY 2013 to $68.7 million and $73.0 million in, respectively, FYs 2014 and 2015) and Supervision, Enforcement and Fair Lending (increasing from $105.5 million in FY 2013 to $165.3 million and $174.7 million in, respectively, FYs 2014 and 2015). For Consumer Education and Engagement, however, one of the CFPB’s primary missions, the budget only includes $31.5 million for FY 2014 and $38.5 million in FY 2015.
The report breaks down the total budget by goals, programs and spending categories. In FYs 2014 and 2015, 47% (or nearly half) of the total budget is allocated to the first of the CFPB’s goals described below, which encompasses the CFPB’s rulemaking, enforcement and supervisory activities. The report also shows the number of full time employees (FTE) by program. For FY 2014, 742 out of a total of 1,624 FTEs are assigned to Supervision, Enforcement, and Fair Lending. For FY 2015, those numbers increase to 834 and 1,796, respectively. According to the report, “[m]ore than 45% of the growth in staff over the next two fiscal years will support the Supervision, Enforcement, and Fair Lending Division, while the Bureau continues to staff its regional examination workforce.”
With respect to the CFPB’s progress in meeting its goal of “prevent[ing] financial harm to consumers while promoting good practices that benefit them,” the report reviews the CFPB’s enforcement activities and indicates that the CFPB (1) opened 160 “supervisory actions during FY 2013 at large banks and nonbank financial institutions” which included “the first ever review of consumer reporting agencies and nonbank debt collectors,” (2) hired 114 more examiners and completed hiring of all four Regional Directors, and (3) opened 10 new targeted ECOA exams focused on mortgage and auto lending and 37 new HMDA integrity exams.
While providing information about enforcement actions, the report provides no information on CFPB investigations. For example, without revealing names, the CFPB could readily have provided the total number of investigations it has conducted broken down by industry and indicating whether the investigation was closed without action, resulted in the initiation of an enforcement action or is still pending.
To demonstrate its progress in meeting its goal of “empower[ing] consumers to live better financial lives,” the CFPB discusses the increase in consumer complaint volume, its efforts to more efficiently process complaints, and its consumer education resources and initiatives.
The CFPB’s two other strategic goals are to “inform the public, policy makers, and the CFPB’s own policy-making with data-driven analysis of consumer finance markets and consumer behavior” and to “advance the CFPB’s performance by maximizing resource productivity and enhancing impact.”
With respect to its progress in meeting the first goal, the CFPB discusses its collection of data on the mortgage and credit card markets (which it has defended against charges that such collections violate consumer privacy rights) and various reports it has issued such as those on payday loans, deposit advance products and overdraft programs.
The CFPB’s discussion of its progress with respect to meeting the second goal includes its efforts to grow and engage its workforce, engage the public through field hearings, award contracts competitively, build the infrastructure necessary to effectively make payments from the Civil Penalty Fund, and release datasets to the public. According to the report, in addition to the online tool it unveiled last month to facilitate public access to HMDA data, the CFPB plans to release “two more large datasets in FY 2014.”