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Nov 13, 2012
Categories: Consumer Lending Home-Secured Lending Operations

More on the CFPB's Strategic Plan for 2013-2018

Written by Steve Van Beek

Last Friday, we blogged on the CFPB's Strategic Plan for 2013 through 2018.  Today I wanted to review a couple aspects of the plan.  Initially, it makes sense to take a step back and look at the structure of the Strategic Plan:

  • 4 strategic goals that outline what we aim to achieve
  • 11 desired outcomes in support of our goals
  • 25 strategies that state the actions we will take to accomplish our outcomes
  • 27 performance measures that we will track against specific targets in order to assess our progress toward achieving our outcomes
  • 4 performance indicators that we will track and use to assess progress toward achieving our outcomes. Unlike performance measures, indicators do not reflect targets

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Consumer Complaint Volume.  We blogged numerous times about the CFPB's Consumer Complaint Database and the lack of verification of complaints (as well as the CFPB's ineffective disclaimer).  

With this in mind, it was very disheartening to see this performance measure regarding consumer complaints:

"COMPLAINT VOLUME:  Number of consumer complaints handled"

Not to beat a dead horse, but why should the performance measure be quantitative rather than qualitative.  Shouldn't the measure relate to whether or not the submitted complaints were, in fact, valid?  Are consumers protected if the complaint volume increases?  Or are consumers protected if valid complaints are submitted and addressed?  

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Regulation Reviews.  Another interesting performance measure is the CFPB's completion of their review of existing regulations:

"% OF ON-SCHEDULE REGULATION REVIEWS:  The percentage of five-year regulation reviews completed on schedule"

If the CFPB's current streamlining initiative is any indication, the CFPB has put reducing regulatory burden very low on their priority list.  Hopefully they will place a greater focus on this issue in the future.  After all, credit unions (and the super-majority of other entities offering financial products and services) want to comply.  However, they are often faced with extremely complex or severely outdated regulations which make the process much harder than it needs to be.  

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Of course, there is much more information in the Strategic Plan and I encourage you to share this with your management teams and Boards.  

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