The Office of Inspector General (OIG) for the CFPB and Fed has issued a report on the results of its evaluation of the effectiveness of the CFPB’s Examiner Commissioning Program (ECP) and On-the-Job Training (OJT) Program. In conducting the evaluation, the OIG assessed the design, implementation, and execution of the two programs. The OIG found that the effectiveness of both programs could be improved.
The CFPB implemented the ECP in October 2014 and, according to the report, has described the ECP as “critical” for its supervision program and the professional development of its examiners. Although the OIG found that the CFPB had taken some steps to enhance the ECP, it identified several shortcomings. The OIG found the following:
- Due to management’s workforce needs and advancement incentives, some examiners appeared to proceed through certain components of the ECP before being fully prepared. In addition, certain controls established by the CFPB to manage examiners’ progression through the ECP might be ineffective.
- Some examiners did not appear to receive adequate training and developmental opportunities or exposure to certain CFPB internal processes before proceeding to certain components of the ECP.
- The CFPB did not have a formal method to evaluate and update the ECP.
- The CFPB did not consistently communicate ECP requirements to prospective employees, including the starting point for the 5-year requirement for completing the ECP.
The CFPB’s OJT program is intended to be a standardized program that ensures examiners are trained uniformly across all regions. In the program, an OJT trainer is expected to work with an examiner on an examination, provide mentoring, discuss the CFPB’s Supervision and Examination Manual, and oversee the examiner’s completion of assigned modules. The OIG found that CFPB regions had not consistently implemented the OJT program and examiners may not have understood the requirements, expectations, and purpose of the OJT.
The report makes a series of recommendations for addressing the OIG’s findings and enhancing the effectiveness of the ECP and OJT program. In the CFPB’s response to the OIG’s draft report, which is included with the report, the CFPB states that it agrees with the OIG’s recommendations and outlines its plans for implementing the recommendations.