April 2013

Consumer Financial

Protection Bureau

Strategic Plan

FY 2013 - FY 2017
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2 CFPB STRATEGIC PLAN FY 2013 - FY 2017

Table of Contents

Table of Contents ........................................................................................ 2

Overview of the CFPB ................................................................................ 4

Plan Overview.............................................................................................. 8

Goal 1............................................................................................................ 9

Outcome 1.1: Create, adopt, and administer regulations in order to promote a

consumer financial marketplace in which: (A) consumers can understand the costs,

benefits, and risks associated with consumer financial products and services

initially and over the term of the product or service, and (B) consumers are not

subject to deceptive, unfair, abusive, or discriminatory practices. .......................... 10

Outcome 1.2: Supervise institutions to foster compliance with Federal consumer

financial laws, promote a fair consumer financial marketplace, and prevent unlawful

discrimination. ................................................................................................................. 12

Outcome 1.3: Enforce Federal consumer financial laws and hold violators

accountable...................................................................................................................... 12

Goal 2.......................................................................................................... 16

Outcome 2.1: Collect, monitor, respond to and share data associated with

consumer complaints and inquiries regarding consumer financial products or

services. ............................................................................................................................ 17

Outcome 2.2: Help consumers understand the costs, risks, and tradeoffs of

financial decisions; build trusted relationships that are interactive and informative

to help consumers take control of their financial choices to meet their own goals;

and raise effectiveness of those who provide financial education services to

increase financial literacy. .............................................................................................. 20

Goal 3.......................................................................................................... 24

Outcome 3.1: Monitor markets and conduct research to surface financial trends

and emergent risks relevant to consumers.................................................................. 25
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Outcome 3.2: Articulate a research-driven, evidence-based perspective on

consumer financial markets, consumer behavior, and regulations to inform the

public discourse, inform Bureau thinking on priority areas, identify areas where

Bureau intervention may improve market outcomes, and support efforts to reduce

outdated, unnecessary, or unduly burdensome regulations. ................................... 26

Goal 4.......................................................................................................... 28

Outcome 4.1: Attract, engage, and deploy a workforce that meets dynamic

challenges and provides effective oversight of the consumer financial

marketplace. .................................................................................................................... 28

Outcome 4.2: Enable the innovative use of technology for the benefit of efficient

internal processes and effective public engagement. ............................................... 30

Outcome 4.3: Enable the operation of a high-performing organization by ensuring

effective and efficient management, protection of the CFPB resources, rigorous

internal controls, and full compliance with the law. ................................................... 31

Outcome 4.4: Increase public confidence in consumer financial markets by

maintaining the CFPB’s transparency, accountability, and meaningful channels for

feedback........................................................................................................................... 33

Appendix.................................................................................................... 35

Endnotes..................................................................................................... 39
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Overview of the CFPB

The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) was established under Title

X of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act").

To create a single point of accountability in the federal government for consumer financial

protection, the Dodd-Frank Act consolidated many of the consumer financial protection

authorities previously shared by seven federal agencies into the CFPB and provided the

Bureau with additional authorities to: ▪ Conduct rulemaking, supervision and enforcement with respect to the Federal

consumer financial laws; ▪ Handle consumer complaints and inquiries; ▪ Promote financial education; ▪ Research consumer behavior; and, ▪ Monitor financial markets for risks to consumers. 

OUR ORGANIZATION

The Bureau performs its work through six Divisions, described below. Our organizational

chart is displayed in the appendix of this document.

Division descriptions

Supervision,

Enforcement,

and Fair Lending

Ensures compliance with Federal consumer financial laws by

supervising market participants and bringing enforcement actions

when appropriate. 

Research,

Markets, and

Regulations

Responsible for understanding consumer financial markets and

consumer behavior, evaluating whether there is a need for

regulation, and determining the costs and benefits of potential

or existing regulations. 
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OUR MISSION

The CFPB is a 21st century agency that helps consumer finance markets work by making rules

more effective, by consistently and fairly enforcing those rules, and by empowering

consumers to take more control over their economic lives.

OUR VISION

If we achieve our mission, then we will have encouraged the development of a consumer

finance marketplace

▪ where customers can see prices and risks up front and where they can easily make

product comparisons; ▪ in which no one can build a business model around unfair, deceptive, or abusive

practices; ▪ that works for American consumers, responsible providers, and the economy as a

whole.

Consumer

Education and

Engagement

Provides, through a variety of initiatives and methods, information

to consumers that will allow them to make decisions that are best for

them. Consumer education is a central mission of the Bureau. The

Bureau is developing targeted outreach to groups that face

particular challenges, as required by the Dodd-Frank Act.

Legal Division Responsible for the Bureau’s compliance with all applicable laws

and provides advice to the Director and the Bureau’s divisions.

External Affairs Manages the Bureau’s relationships with external stakeholders and

ensures that the Bureau maintains robust dialogue with interested

stakeholders to promote understanding, transparency,

and accountability.

Operations Builds and sustains the CFPB’s operational infrastructure to support

the entire organization. The division also includes the Office of

Consumer Response, which handles consumer complaints and

inquiries related to consumer financial products and services.
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WE WILL ACHIEVE OUR MISSION AND VISION

THROUGH

WE AIM TO EMBODY THE FOLLOWING VALUES IN

EVERYTHING WE DO

Data-driven analysis

The CFPB is a data-driven agency. We take in data, manage it, store

it, share it appropriately, and protect it from unauthorized access.

Our aim is to use data purposefully, to analyze and distill data to

enable informed decision-making in all internal and external

functions.

Innovative use of technology

Technology is core to the CFPB accomplishing its mission. This

means developing and leveraging technology to enhance the CFPB’s

reach, impact, and effectiveness. We strive to be recognized as an

innovative, 21st century agency whose approach to technology

serves as a model within government.

Valuing the best people and great teamwork

At the CFPB, we believe our people are our greatest asset. Therefore,

we invest in world-class training and support in order to create an

environment that encourages employees at all levels to tackle

complex challenges. We also believe effective teamwork extends

outside the walls of the CFPB. We seek input from and collaborate

with consumers, industry, government entities, and other external

stakeholders.

Service

Our mission begins with service to the consumer and our country.

We serve our colleagues by listening to one another and by sharing

our collective knowledge and experience.
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Leadership

Fostering leadership and collaboration at all levels is at the core of

our success. We believe in investing in the growth of our colleagues

and in creating an organization that is accountable to the American

people.

Innovation

Our organization embraces new ideas and technology. We are

focused on continuously improving, learning, and pushing ourselves

to be great.
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Plan Overview

OUR STRATEGIC PLAN ARTICULATES FOUR GOALS

IN SUPPORT OF EACH GOAL WE OUTLINE

GOAL 1 Prevent financial harm to consumers while promoting good

practices that benefit them.

GOAL 2 Empower consumers to live better financial lives. 

GOAL 3 Inform the public, policy makers, and the CFPB’s own policymaking with data-driven analysis of consumer finance markets and

consumer behavior.

GOAL 4 Advance the CFPB’s performance by maximizing resource

productivity and enhancing impact.

OUTCOMES Desired outcomes that further define the focus of our work.

STRATEGIES &

INVESTMENTS

Strategies and investments that lay out the actions we will take to

accomplish our outcomes.

PERFORMANCE

GOALS

Specific, measurable goals we will use to assess our progress.
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Goal 1

Prevent financial harm to consumers while promoting

good practices that benefit them.

Prior to Congress enacting the Dodd-Frank Act, consumer financial protection had not been

the primary focus of any one federal agency, and no agency could set the rules for the entire

financial market. The result was a system without sufficiently effective rules or consistent

enforcement of the law. The absence of such a regulating entity and corresponding rules

ultimately contributed to the 2008 financial crisis.

Consumer financial protection is the CFPB’s singular focus. The Dodd-Frank Act increased

accountability in government by consolidating consumer financial protection authorities that

had existed across seven different federal agencies into one, the newly formed Consumer

Financial Protection Bureau. These authorities include the ability to issue regulations under

more than a dozen Federal consumer financial laws. As provided in section 1021 of the DoddFrank Act, the purpose of the CFPB is to implement and enforce Federal consumer financial

laws consistently for the purpose of ensuring that all consumers have access to markets for

consumer financial products and services and that such markets are fair, transparent, and

competitive.

In addition, the Dodd-Frank Act gives the CFPB the authority to supervise and examine many

non-bank financial service providers previously unsupervised at the federal level, such as

mortgage companies, payday lenders, private education lenders, and larger debt collectors

and consumer reporting companies. With the consolidation of existing and new authorities

under one roof, the CFPB is now focused and equipped to prevent financial harm to

consumers while promoting practices that benefit consumers across financial institutions.

Industry structure is always changing, and therefore, so too will the number of institutions

that fall under the CFPB’s supervisory authority. The CFPB is designed to be agile and adjust

its approach to supervising the financial industry in order to respond rapidly to changing

consumer needs.
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THE CFPB WILL ACCOMPLISH ITS FIRST GOAL BY

ACHIEVING THREE OUTCOMES

Establish and maintain an effective

regulatory environment via outcome

1.1

Foster and enforce compliance with

Federal consumer financial laws via

outcomes 1.2 and 1.3

Establish and

maintain an

effective regulatory

environment

Outcome 1.1: Create, adopt, and

administer regulations in order to

promote a consumer financial

marketplace in which: (A) consumers

can understand the costs, benefits, and

risks associated with consumer financial

products and services initially and over

the term of the product or service, and

(B) consumers are not subject to

deceptive, unfair, abusive, or

discriminatory practices.

Outcome leader: Associate Director of Research, Markets, and

Regulations
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THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

THREE PERFORMANCE GOALS

Performance goal 1.1.1: Complete consumer protection related

rulemakings within nine months of receipt of final public comments.

The Bureau has made it a priority to ensure that it puts consumer protection regulations into

place, including those implementing statutory requirements, in a timely manner. For this

reason, the Bureau believes that completion of its own regulatory proposals within 9 months

of the close of the public comment period is a good measure of whether it is meeting this goal.

Strategies Develop and maintain an efficient fact-based

approach to developing, evaluating, revising, and

finalizing regulations.

Develop a rule-writing team with highly advanced

skills in relevant and specialized legal and business

areas.

Work with consumers and industry stakeholders on

developing regulations to implement existing

Federal consumer financial laws effectively.

Leverage technology to continuously improve the

efficiency and effectiveness of the federal

rulemaking processes and procedures. 

Develop ways to provide financial product

disclosure information to consumers electronically.

Working with industry groups, develop data

standards so that private enterprise can create new

tools that help consumers understand the financial

products they buy.
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Performance goal 1.1.2: Complete all five-year regulation

assessments on schedule.

Section 1022(d) of the Dodd-Frank Act requires the CFPB to assess each significant rule the

Bureau adopts and publish a report of the assessment within five years of the effective date.

The assessment addresses, among other factors, the rule’s effectiveness in meeting the

purposes and objectives of the Dodd-Frank Act, Title X and the specific goals the Bureau

states for the rule.

Performance goal 1.1.3: Ensure that all rulemakings are

informed by public outreach processes, such as Small Business

Regulatory Enforcement Fairness Act (SBREFA) panels and consumer

and industry roundtables.

The Regulatory Flexibility Act, as amended by SBREFA and the Dodd-Frank Act, requires the

Bureau to convene a Small Business Review Panel before proposing a rule that will have a

significant economic impact on a substantial number of small entities. Other public outreach

efforts, such as meetings with consumers and industry stakeholders in the development of a

proposal, inform and otherwise assist the Bureau in crafting more effective rules. The Bureau

is also interested in exploring ways to increase general consumer involvement in the

rulemaking process.

foster and enforce

compliance with

consumer financial

protection law

Outcome 1.2: Supervise institutions to

foster compliance with Federal

consumer financial laws, promote a fair

consumer financial marketplace, and

prevent unlawful discrimination.

Outcome 1.3: Enforce Federal

consumer financial laws and hold

violators accountable.

Outcome leader: Associate Director of Supervision, Enforcement,

and Fair Lending
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THESE OUTCOMES WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

EIGHT PERFORMANCE GOALS

Performance goal 1.2.1 / 1.3.1: Perform supervision activities

at financial services institutions under the CFPB's jurisdiction to foster

compliance with Federal consumer financial laws.

The CFPB’s Supervision, Enforcement, and Fair Lending Offices collaborate to

conduct supervisory activities at bank and nonbank institutions. The CFPB’s supervisory

authority includes banks, thrifts, and credit unions with over $10 billion in assets, and their

affiliates, as well as certain nonbank consumer financial service providers, such as mortgage

lenders, brokers, and servicers; private education lenders; payday lenders; and larger

Strategies Acquire and analyze qualitative and quantitative

information and data pertaining to consumer

financial product and service markets and

companies.

Focus resources on institutions and their product

lines that, based on their size, nature of the product,

and field and market intelligence, pose the greatest

risk to consumers.

Establish a framework for sharing information,

coordinating activity, and promoting best practices

with fellow financial institution supervisory and law

enforcement agencies to ensure the most effective

use of regulatory resources.

Continue to develop a technology solution for

coordinating supervisory information, capable of

recording, storing, tracking, and reporting

information on the CFPB’s supervisory process.

Continue implementing a tool capable of reviewing

loan and deposit portfolios for compliance with

Federal consumer financial laws.
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participants of the consumer reporting and debt collection markets. These supervisory

activities will foster compliance with Federal consumer financial laws, promote a fair

consumer financial marketplace, and prevent unlawful discrimination.

Performance goal 1.2.2 / 1.3.2: Effectively initiate supervisory

activities at financial services institutions under the CFPB's jurisdiction

to determine compliance with the Federal fair lending laws, including

the Equal Credit Opportunity Act (ECOA) and the Home Mortgage

Disclosure Act (HMDA).

The Bureau’s supervision activities range from assessments of the institution’s fair lending

compliance management systems to in-depth reviews of products or lending activities that

may pose heightened fair lending risks to consumers. This indicator focuses on the Bureau’s

in-depth fair lending reviews.

Performance goal 1.2.3 / 1.3.3: Issue examination reports

within the CFPB's established time periods following the close of

examinations.

Effective supervision of financial institutions to foster compliance with Federal consumer

financial laws requires prompt notice to institutions of matters requiring their attention and

action to avoid further violations or consumer harm. A thorough report development and

review process ensures high quality reports that appropriately explain what the examination

team found and why corrective actions, if any, are required.

Performance goal 1.2.4 / 1.3.4: Supervisory matters requiring

attention resolved by the prescribed timeframe.

The CFPB monitors institutions receiving notice of matters requiring attention to ensure that

corrective actions are taken by the prescribed timeframe in response to supervisory activities,

which foster compliance with Federal consumer financial laws and promote a fair consumer

financial marketplace. 
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Performance goal 1.2.5 / 1.3.5: Cooperate and share

information with its partners in local, state, and federal law enforcement

as part of its efforts to protect consumers, deter wrongdoers, and build

a better marketplace.

This indicator ensures that the CFPB works well with its partners at the local, state, and

federal level to share information, subject to the Bureau's regulations and policies on

information sharing, across jurisdictions and to make the best use of limited resources.

Performance goal 1.2.6 / 1.3.6: Where the Bureau determines

enforcement action is warranted, file or settle action within two years of

opening its investigation.

Filing enforcement actions in a timely manner is an important measure of the CFPB’s

effectiveness. The Bureau seeks to balance the need to effectively pursue complex and timeconsuming cases while minimizing any unnecessary delay between conduct and resolution.

Timely pursuit of resolutions increases deterrence and provides consumers with greater

protections of law.

Performance goal 1.2.7 / 1.3.7: Successfully resolve the cases

the CFPB files in court and administrative adjudicative proceedings

whether by litigation, settlement, issuance of a default judgment, or

other means.

This measure ensures that the CFPB successfully resolves as many actions as possible while,

at the same time, pursuing complex and challenging actions when appropriate, even when

success is not assured.

Performance goal 1.2.8 / 1.3.8: Successfully resolve the fair

lending cases the CFPB files in court and administrative adjudicative

proceedings, whether by litigation, settlement, issuance of a default

judgment, or other means.

When the Dodd-Frank Act created within the CFPB an Office of Fair Lending, it set forth as

one of that Office’s functions the enforcement of Federal fair lending laws, including

ECOA and HMDA. The CFPB seeks to successfully resolve as many fair lending actions as

possible while, at the same time, pursuing complex and challenging actions when appropriate,

even when success is not assured. 
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Goal 2

Empower consumers to live better financial lives.

The CFPB works to arm consumers with the knowledge, tools, and capabilities they need in

order to make better-informed financial decisions by engaging them in the right moments of

their financial lives, in moments when they are most receptive to seeking out and acting on

assistance. To that end, the CFPB will develop and maintain a variety of tools, programs, and

initiatives that provide targeted, meaningful, and accessible assistance and information to

consumers at the moment they need it.

While almost all Americans are impacted by financial products2

Many face challenges in making financial decisions3

20% of individuals reported that over the past year, their household spent

more than their income.

60% of individuals lack a rainy day fund to cover expenses even for three

months in case of emergencies.

62% of individuals said that, when obtaining their most recent credit

card, they did not collect and compare information about cards from

more than one company. 
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Differences in financial education, capabilities, and skills contribute to this problem.

Consumers represent diverse populations with diverse financial needs, choices, and

challenges; they seek out information about financial choices using a variety of channels.

Therefore, the CFPB must be flexible and adaptable in addressing the highly diverse needs of

American consumers.

Despite this diversity, consumers often find themselves in one of four specific financial

circumstances at various points in their lives. These stages include learning about financial

life, losing financial ground, bottoming out, or gaining financial ground.

THE CFPB WILL ACCOMPLISH ITS SECOND GOAL BY

ACHIEVING TWO OUTCOMES

Path of consumer

behavior

prevent and respond

to problems 

Outcome 2.1: Collect, monitor, respond

to and share data associated with

consumer complaints and inquiries

regarding consumer financial products

or services.

Outcome leader: Associate Director, Operations
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The CFPB provides direct assistance to consumers, in real time, through its Office of

Consumer Response. Consumer Response hears directly from consumers about the

challenges they face in the marketplace, brings their concerns to the attention of companies,

and assists in addressing their complaints.

Top consumer complaints

The CFPB’s Office of Consumer Response looked to the experiences of other regulators to

understand the types of complaints to expect and used available complaint data to inform its

phased rollout of complaint handling by product. 

Consumer complaint categories

Top complaint categories in the FTC Consumer Sentinel Network database (2011)4

THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

Strategies Collect, analyze, and leverage Consumer Response

operational data to enable continuous improvement

of our services to consumers.
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WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

THREE PERFORMANCE GOALS

Performance goal 2.1.1: Decrease time between receiving and

closing a complaint.

Facilitating efficient handling of a consumer complaint is a key way in which the CFPB

provides targeted, meaningful, and accessible assistance and information to empower

consumers.

Performance goal 2.1.2: Facilitate the timely response to

consumer complaints by companies.

The CFPB facilitates timely response to consumer complaints by using a dedicated company

portal to route complaints to companies for response. Once routed, complaints appear in real

time in company portals where companies can review and respond to the complaint,

triggering communications to consumers about the company’s response to their complaints.

Develop a seamless approach to delivery of

appropriate and useful Consumer Response data

within the CFPB and to the public so that

information is timely, understandable, and

maintains consumer privacy.

Automate key internal operational systems,

particularly the intake and routing process, in order

to effectively scale Consumer Response operations.

Maintain a robust training and development

program to support Consumer Response operations

as volume and product coverage increase.
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Performance goal 2.1.3: Expand capacity to handle consumer

complaints.

Consumer complaints shed light on the challenges consumers face in obtaining financial

products and services and inform the CFPB’s efforts to make consumer financial markets

work better and empower consumers to live better financial lives. 

The CFPB works to provide consumers with the information, knowledge, and financial

education needed in order to make well-informed decisions to enhance the financial

knowledge and capability of the country as a whole. In addition to improving overall financial

capability, the CFPB focuses on addressing the unique financial challenges faced by four

specific populations.

STUDENTS

 Population enrolled in colleges and universities5

28 million

enable better

financial lives

Outcome 2.2: Help consumers

understand the costs, risks, and

tradeoffs of financial decisions; build

trusted relationships that are interactive

and informative to help consumers take

control of their financial choices to meet

their own goals; and raise effectiveness

of those who provide financial

education services to increase financial

literacy.

Outcome leader: Associate Director, Consumer Education and

Engagement
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The benefits of higher education are well documented. Four-year college graduates experience

a number of economic benefits over high school graduates, including higher median earnings

and lower unemployment rates. Evidence indicates that these disparities are growing.6

Demand for higher education and college financing are at all-time highs. Over the past

decade, the size of the student loan market has been increasing steadily. At over $1 trillion in

loans outstanding, the market for student loans is now the second largest component of

household debt after mortgages.7

OLDER AMERICANS

Population age 62 and older8

50 million

Aging poses a number of unique financial challenges. Older Americans face complicated

decisions about finances, retirement, and long-term planning. With the shift from definedbenefit to defined-contribution plans and other forms of “do-it-yourself retirement” such as

IRAs, good financial advice and assistance is especially important. Older Americans are

frequently targeted for scams and financial exploitation. As people age, their ability to handle

finances may decline, putting them at risk of making poor decisions or increasing the risk that

they will become victims of financial exploitation by scam artists or even by family members

or legal fiduciaries.

SERVICEMEMBERS

Population (including veterans)9

22 million

The CFPB believes servicemembers should be able to accomplish their mission without

worrying about illegal or harmful financial practices. Military life has extra challenges with

powerful financial repercussions for uniformed military personnel, veterans, military retirees,

and their families.

LOW-INCOME AND ECONOMICALLY VULNERABLE

Population 
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68 million

Adults are unbanked or underbanked10

46 million

Live below the official poverty line11

Many consumers cannot or do not access banks, thrifts, or credit unions, and instead, rely on

alternative financial services. Low-income and other economically vulnerable consumers are

especially likely to use these services. The CFPB focuses on identifying approaches that help

this population achieve economic stability and works to ensure that the financial marketplace

works for all consumers, including those who have been traditionally underserved.

THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

Strategies Provide tools and information directly to the public

to help individuals make decisions about money

that will serve their own life goals.

Analyze consumer financial experiences to help

shape policy and influence product change to make

the financial environment safer and more beneficial

for consumers.

Reshape the field of financial education through the

identification and widespread dissemination of

effective practices.

Collaborate with third parties to encourage the

development of effective financial skills and habits.
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WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

THREE PERFORMANCE GOALS

Performance goal 2.2.1: Significantly increase targeted

outreach activities and digital education materials in order to engage

consumers at the right moment.

The CFPB works to arm consumers with the knowledge, tools, and capabilities they need in

order to make better informed financial decisions by engaging them in the right moments of

their financial lives, in moments when the consumer is most receptive to seeking out and

acting on assistance. To that end, the CFPB will develop and maintain a variety of tools,

programs, and initiatives that provide targeted, meaningful, and accessible assistance and

information to consumers at the moment they need it.

Performance goal 2.2.2: Improve the understanding of

successful financial decision-making approaches by identifying key

success factors in financial health.

The CFPB believes that financial education’s primary goal is to improve the financial wellbeing of consumers. However, very little empirical research has been conducted regarding

what variables measure financial health in terms of real-world outcomes for consumers. By

defining these variables through data-driven research the Bureau will be able to define what

knowledge and skills are associated with financial health. The Bureau will then encourage

effective teaching and development of that knowledge and skills by enhancing the

effectiveness of financial education and financial capability work in the United States.

Performance goal 2.2.3: Promote fair lending compliance and

education by lending and participating in fair lending outreach

activities.

As one of its core functions, the Office of Fair Lending is responsible for “working with private

industry, fair lending, civil rights, [and] consumer and community advocates on the

promotion of fair lending compliance and education.” (Dodd-Frank Act, Section 1013(c)(2)

(c).) CFPB employees travel throughout the country to meet with industry and advocate

groups focused on fair lending issues. Consumer advocates communicate directly with the

CFPB, and the CFPB learns about emerging fair lending issues from these groups.
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Goal 3

Inform the public, policy-makers, and the CFPB’s own

policy-making with data-driven analysis of consumer

finance markets and consumer behavior.

Understanding how consumer financial markets work, the avenues for innovation in financial

products and services, and the potential for risk to consumers is a core component of the

CFPB’s mission. The CFPB’s aim is to ground all of its work — from writing rules and

litigating enforcement actions to its outreach and financial literacy efforts — in the realities of

the marketplace and the complexities of consumer behavior.

This requires a repository for data; strong partnerships within the CFPB and externally to

ensure that we continue to monitor markets effectively; technology tools, and employees with

the skills and capabilities needed to analyze data and distill insights.

The CFPB’s research will support building an understanding of the markets we regulate and

the nature of consumer behavior in these markets. It will also support the consideration of the

potential benefits and costs of the CFPB’s work to consumers and institutions, including

effects on access by consumers to consumer financial products or services.

In all of the data used for its analyses, the Bureau will work to ensure that strong protections

are in place around personally identifiable information. Datasets will aggregate information

such that no information is personally attributable or identifiable, and research/analysis

products resulting from such data will use similarly anonymous information as appropriate.

The Bureau treats the information collected from participating persons and institutions

consistently with our confidentiality regulations and all data and analyses are subject to legal

and privacy review prior to their release.
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THE CFPB WILL ACCOMPLISH ITS THIRD GOAL BY

ACHIEVING TWO OUTCOMES

THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

Perform evidence-based analysis via

Outcome 3.1

Disseminate data and use it to inform

decision-making via Outcome 3.2

Outcome 3.1: Monitor markets and

conduct research to surface financial

trends and emergent risks relevant to

consumers.

Outcome leader: Associate Director, Research, Markets, and

Regulations

Strategies Acquire, collect, and maintain the data necessary to

properly monitor select markets for emerging risks

and positive innovations.

Coordinate with other federal agencies, including

the Treasury Office of Financial Research, to ensure

the most efficient use of data and avoid duplication.
CONSUMER FINANCIAL PROTECTION BUREAU

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WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

PERFORMANCE GOAL

Performance goal 3.1.1: Monitor the credit card and mortgage

markets through data.

The credit card and mortgage markets are both critical to consumers. Having quantitative

data on both markets makes it easier for the Bureau to monitor trends and implications for

both consumers and providers. These data also strengthen the evidentiary basis for Bureau

policy-making.

Outcome 3.2: Articulate a researchdriven, evidence-based perspective on

consumer financial markets, consumer

behavior, and regulations to inform the

public discourse, inform Bureau thinking

on priority areas, identify areas where

Bureau intervention may improve

market outcomes, and support efforts to

reduce outdated, unnecessary, or

unduly burdensome regulations.

Outcome leader: Associate Director, Research, Markets, and

Regulations

Build and maintain technological infrastructure

required to support market intelligence through the

integration of diverse internal and external data.
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THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

PERFORMANCE GOAL

Performance goal 3.2.1: Increase the number of reports

produced about specific consumer financial products, markets, or

regulations and on consumer decision-making.

The Bureau conducts qualitative and quantitative research to deepen understanding of

consumer decision making; consumer financial products and markets; and the effects of

consumer financial regulations and policies. Periodically, the Bureau publishes reports of its

research.

Bureau and independent research are intended to provide the Bureau and other policymakers with a stronger evidentiary foundation for policy-making. They are also intended to

inform the public and enhance the public’s participation in policy-making.

Strategies Collect and analyze data in order to improve

understanding, regulation, and functioning of

consumer financial markets and behavior.

Help to make the market safer for special

populations such as students, older Americans,

servicemembers and veterans, and economically

vulnerable consumers through selected policy work.

Institutionalize cross-Bureau collaboration to

ensure our work is informed by the CFPB’s internal

research and expertise.

Develop and maintain the tools and technology

required to effectively, efficiently, and securely

disseminate data and research for internal and

external audiences.
CONSUMER FINANCIAL PROTECTION BUREAU

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Goal 4

Advance the CFPB’s performance by maximizing

resource productivity and enhancing impact.

In order to maximize the effectiveness of the consumer protections established by Federal

consumer financial law, the CFPB must acquire, maintain, support, and direct its resources in

a way that enables it to operate efficiently, effectively, and transparently. This means

developing, maintaining, and continuously improving the policies and controls in place to

ensure the CFPB has the resources it needs and puts those resources to the best use possible.

A key mission of the CFPB is to make financial products and services more transparent in the

consumer marketplace. The CFPB will strive to achieve the same level of commitment to

transparency in its own activities, while respecting consumer privacy and confidentiality. To

accomplish this, the CFPB will develop and implement mechanisms and provide channels to

maintain an open, collaborative dialogue with the public.

Outcome 4.1: Attract, engage, and deploy a workforce

that meets dynamic challenges and provides effective

oversight of the consumer financial marketplace.

Outcome leader: Associate Director, Operations

As a relatively new government agency, the CFPB has a unique and vital opportunity to create

an innovative, 21st century organization. To that end, the CFPB will continue to identify and

adopt best practices from the private and public sectors to hire, train and develop a diverse

world-class workforce with the knowledge, skills and abilities required to effectively achieve

our mission. 

THIS OUTCOME WILL BE ACCOMPLISHED BY THE FOLLOWING

STRATEGIES

Strategies Recruit and retain a high-quality, diverse staff

through effective workforce planning and talent

acquisition methods, strong engagement, a
CONSUMER FINANCIAL PROTECTION BUREAU

29 CFPB STRATEGIC PLAN FY 2013 - FY 2017

A more detailed discussion of the strategies and activities in support of this outcome are

included in the Bureau's annual report to Congress on human capital activities. WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING TWO

PERFORMANCE GOALS

Performance Goal 4.1.1: Recruit and retain high-performing,

diverse employees with the right skills and abilities to meet mission

driven goals and objectives.

A wide array of skills and abilities, which represent diversity and organizational makeup, is

required for success in achieving our mission. We will assess progress toward achieving this

goal using a workforce profile metric and a measure of employee and manager assessments of

the skills of the workforce.

Performance goal 4.1.2: Increase the level of employee

engagement.

Engagement has been described as a state of passion and commitment to the organization’s

goals on the part of each employee, which leads to their willingness to invest discretionary

effort to ensure success. In the case of the Bureau, maintaining the initial motivation and

comprehensive diversity and inclusion program,

and a competitive compensation and benefits

package.

Create and sustain a high-performing workforce

through innovative workforce learning,

development and performance-management

programs.

Develop human capital infrastructure by creating

human capital policies, improving human capital

information systems, effectively allocating and

prioritizing resources, and using mutual

accountabilities to achieve desired human capital

outcomes. 
CONSUMER FINANCIAL PROTECTION BUREAU

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excitement of the new workforce is critical to our future success. Individual employees’

perception of the level of employee engagement is one way to measure the Bureau’s success

engaging its employees. 

Outcome 4.2: Enable the innovative use of technology

for the benefit of efficient internal processes and

effective public engagement.

Outcome leader: Associate Director, Operations

The CFPB is committed to staying on the leading edge of technology and leveraging its

technological resources to provide significant business value with lower costs. From

developing online products that help inform consumers to making critical data available

internally and to the public, technology is and will continue to be core to the CFPB

accomplishing its mission.

We believe technology has a key role to play in creating an organization that, despite its size

and the physical distance that separates its staff, still feels and acts like a small team instead

of a large bureaucracy. The CFPB will leverage technology to create a streamlined

organization that effectively communicates information across teams and through the

hierarchy, unifies the organization with common tools and methods for getting things done

quickly and easily, and creates a strong culture and an environment of teamwork and

collaboration where all staff members are contributing to each other’s missions.

THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

Strategies Develop a set of implementable data standards that

help consumers shop for financial products.

Build a behavioral research and user testing practice

in order to ensure maximally usable product design.

Build a next-generation open data catalog.

Establish a secure, responsive and cost-effective

technology infrastructure to enable a 21st century

agency.
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WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING TWO

PERFORMANCE GOALS

Performance goal 4.2.1: Release new datasets to the public,

where legally permissible and appropriate, to allow for innovative uses

of the data by individuals, non-profit entities, and businesses for the

benefit of consumers.

The public uses data released by the government to build tools and provide resources to

consumers to help them make the best financial decisions. The CFPB wants to support a

culture of information and transparency by releasing useful data to the public when doing so

is legally permissible and appropriate.

Performance goal 4.2.2: Improve the efficiency of internal

processes and procedures.

Technology can help us improve the efficiency of the CFPB so that we serve more consumers

in a better way.

Outcome 4.3: Enable the operation of a highperforming organization by ensuring effective and

efficient management, protection of the CFPB

resources, rigorous internal controls, and full

compliance with the law.

Outcome leader: Associate Director, Operations

Continue to build, develop and improve nextgeneration online tools that help consumers

understand financial products.

Maintain a robust platform for the public to

visualize and make use of data maintained by the

Bureau, such as consumer complaint data.
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32 CFPB STRATEGIC PLAN FY 2013 - FY 2017

The CFPB has the obligation to act as a good steward of public funds. The CFPB will monitor

its operations and conduct periodic evaluations to ensure it maintains good financial practices

and robust internal controls.

THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

THREE PERFORMANCE GOALS

Performance goal 4.3.1: Obtain an unqualified “clean" audit

opinion on the CFPB’s financial statements.

An unqualified opinion from GAO of the CFPB’s internal operations confirms that the Bureau

maintains sound financial practices and robust internal controls.

Performance goal 4.3.2: Award 90% of contracts competitively.

Competing procurement actions allow for competitive market pricing, stronger proposal

submissions, and a distributed vendor base in support of the Bureau. Public value is also

derived as money is being spent effectively.

Strategies Use data to supervise and coordinate all financial

operations of the Bureau consistent with the

requirements of laws and regulations.

Develop a team of high-performing professionals

with expertise in budget, financial management,

procurement, internal controls and travel

operations.

Develop and maintain integrated accounting and

financial management and travel systems in order to

support the effective execution of resources.
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Performance goal 4.3.3: Distribute funds collected through

enforcement actions to identified victims within 24 months.

This goal tracks the disbursement of CPF payments and Bureau-administered redress funds

to eligible identified victims within 24 months of identifying victims. The Dodd-Frank

Act authorizes the CFPB to enforce Federal consumer financial laws. Under this authority, the

CFPB litigates cases which may result in redress to harmed consumers. In some cases, the

Bureau will be responsible for obtaining redress funds from the defendant and distributing

those funds to the harmed consumers. In addition, the Dodd-Frank Act gives the Bureau the

authority to obtain civil money penalties in enforcement actions and to deposit those

penalties in the Civil Penalty Fund. It may then use amounts in the Civil Penalty Fund for

payments to the victims of activities for which civil penalties have been imposed.

Outcome 4.4: Increase public confidence in consumer

financial markets by maintaining the CFPB’s

transparency, accountability, and meaningful channels

for feedback.

Outcome leader: Associate Director, External Affairs

Since transparency is at the core of how the CFPB operates, the CFPB will provide clear

information both on the use of resources and on its performance. To that end, the CFPB will

communicate substantively and frequently across a wide range of external stakeholders,

including industry and consumer groups. The CFPB aims to actively engage all stakeholders

that could potentially be affected by the Bureau, with the understanding that there is much

insight to be gained from varied stakeholders representing distinct points of view.

THIS OUTCOME WILL BE ACCOMPLISHED THROUGH THE

FOLLOWING STRATEGIES

Strategies Gather input from stakeholders on the

CFPB's policies and operations to ensure the Bureau

is effectively communicating its activities, meeting

transparency goals, and actively soliciting feedback.

Enhance program efficiency through regular

analysis of operations data. 
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WE WILL ASSESS OUR PROGRESS THROUGH THE FOLLOWING

PERFORMANCE GOAL

Performance goal 4.4.1: Engage the public by hosting public

field hearings, town hall meetings, Consumer Advisory Board

meetings, and other events on consumer finance issues.

The CFPB aims to engage with the public on consumer finance issues (a) to ensure that

consumers and interested parties have visibility into the Bureau’s work and have meaningful

opportunities to share input publicly and (b) to ensure that the Bureau’s work is informed by

regular input from varied perspectives representing distinct points of view.

Maintain and enhance a highly effective and usable

online presence that supports multiple digital

services.
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Appendix

PROGRAM EVALUATIONS

The CFPB has an expansive, vital mission yet limited resources to achieve its goals. Our vision

helps to guide us in the right direction, our values set expectations for how we get there; and

our strategy helps to focus our energies on areas that offer the greatest potential impact.

It is also important for us to step back, evaluate our recent past performance, and plan for

that which is to come. In order to ensure the Bureau’s programs and strategies are effectively

achieving its goals, the Bureau uses a variety of processes and reports to periodically evaluate

its performance and course correct when necessary.

Government Accountability Office

The GAO conducts studies or investigations related to the CFPB’s programs every year. In FY

2012, GAO’s reports included studies on the benefits and costs associated with implementing

the Dodd-Frank Act; the Dodd-Frank Act’s impact on community banks and credit unions,

troubled mortgages and the Troubled Asset Relief Program; and, the operations of the

Financial Stability Oversight Council and the Office of Financial Research, among other areas.

In addition, GAO performs an annual audit of the CFPB’s financial statements and internal

controls, as required by the Dodd-Frank Act.

Office of the Inspector General of the Board of Governors of the Federal Reserve

System and the Bureau of Consumer Financial Protection

The OIG is an independent oversight authority within the Board of Governors of the

Federal Reserve System that conducts audits of programs and operations of the CFPB

and investigations into allegations of potential misconduct by staff or contractors. The

mission of the OIG is to detect fraud, waste and abuse, and to promote integrity,

economy, efficiency and effectiveness in the CFPB’s programs and operations. The

OIG’s audit reports are available on the OIG’s website.
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Independent Performance Audit

In accordance with the Dodd-Frank Act, the CFPB orders an annual independent

audit of the operations and budget of the Bureau. The purpose of this audit is to

provide objective analyses to improve program performance and operations, reduce

costs, facilitate decision-making, and contribute to public accountability. The audits

for FY 2012 and FY 2011 are available on the Bureau’s website.

Quarterly Performance Reviews

On a quarterly basis, the CFPB executives, including all Goal Leaders, review progress toward

achieving the Bureau's strategic goals and outcomes, in part using the performance goals and

measures outlined in this plan. At these points, course corrections are made as needed.

EXTERNAL CONSULTATION

In accordance with statute, the Bureau sought input from Congress on its Strategic Plan

several times during the drafting process. In addition, the Bureau posted the Strategic Plan on

its website for 30 days in order to give the public the opportunity to provide comments. 

EXTERNAL FACTORS

Key external factors beyond the Bureau’s control have the potential to impact the CFPB’s

ability to effectively achieve its strategic goals and objectives.

It is anticipated that markets in both U.S. and foreign financial services sectors will evolve

over time. These future changes must be monitored, as they will impact the work of the CFPB

in protecting consumers and addressing a continually changing financial environment. 

Additional external factors are discussed throughout the Strategic Plan in the context of our

goals and outcomes.

MANAGEMENT CHALLENGES

The Congress, in implementing the Dodd-Frank Act, followed a long-established precedent in

providing the CFPB with funding outside of the congressional appropriations process to

ensure full independence as the Bureau supervises and regulates providers of consumer

financial products and services and protects consumers. Congress has consistently provided
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37 CFPB STRATEGIC PLAN FY 2013 - FY 2017

for independent funding for bank supervisors to allow for long-term planning and the

execution of complex initiatives and to ensure that banks are examined regularly and

thoroughly for compliance with the law.

The CFPB supervises over 100 very large depository institutions, including the largest,

most complex banks in the country. In addition, it has been charged by Congress with

responsibility for supervising thousands of nonbank providers of consumer financial

products and services. Effective supervision that assures a level playing field between

bank and nonbank institutions requires dedicated and predictable resources, and

independent examiners.

Although Congress provided the CFPB with a source of funding outside the

appropriations process, the CFPB is nonetheless the only bank supervisor with a

statutory cap on its primary source of funding. If the Director were to determine that

the non-appropriated funds to which it is entitled under the Dood-Frank Act are

insufficient to carry out its responsibilities, section 1017 (e) of the Dodd-Frank

Act authorizes the CFPB to also obtain appropriated funds through FY 2014, up to a

capped amount and subject to apportionment. In accordance with the Dodd-Frank

Act and appropriations law requirements, further action would be required on the

part of the Director and Congress in order for the CFPB to obtain such appropriated

funds. These additional funds would be subject to apportionment under section 1517

of Title 31, United States Code, and restrictions that generally apply to the use of

appropriated funds in Title 31, United States Code, and other laws.
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ORGANIZATION CHART

Organizational chart current as of February 27, 2013
CONSUMER FINANCIAL PROTECTION BUREAU

39 CFPB STRATEGIC PLAN FY 2013 - FY 2017

Endnotes

1. Federal Reserve Board, "2010 Survey of Consumer Finances," tables 13 – 10, 6 – 10

based on public data, last updated 7/19/2012, http://www.federalreserve.gov/

econresdata/scf/scf_2010.htm (Last viewed 8/23/2012)

2. Federal Reserve Board, "Changes in U.S. Family Finances from 2007 to 2010: Evidence

from the Survey of Consumer Finances," Federal Reserve Bulletin, Vol 98, No 2, June

2012, pp. 28, 61, http://www.federalreserve.gov/pubs/bulletin/2012/pdf/scf12.pdf

(Last viewed 8/23/2012)

3. FINRA 2009 Investor Education Foundation's Financial Capability Study, http://

www.usfinancialcapability.org (Last viewed 8/23/2012)

4. Federal Trade Commission's Consumer Sentinel Network Data Book for January

through December 2011, February 2012, http://www.ftc.gov/sentinel/reports/sentinelannual-reports/sentinel-cy2011.pdf (Last viewed 8/23/2012)

5. U.S. Department of Education, National Center for Education Statistics, Fall 2009 and

Fall 2010, table prepared February 2012, http://nces.ed.gov/programs/digest/d11/

tables/dt11_230.asp (Last viewed 8/23/2012)

6. College Board Advocacy and Policy Center, "Education Pays 2010 In Brief: The Benefits

of Higher Education for Individuals and Society," 2010, http://trends.collegeboard.org/

sites/default/files/brief/education-pays-2010-in-brief.pdf (Last viewed 2/14/2013)

7. The Department of Education and Consumer Financial Protection Bureau, “Private

Student Loans Report,” July 20, 2012, http://www.consumerfinance.gov/reports/

private-student-loans-report/ (last viewed 9/10/12)

8. U.S. Census Bureau, "The Older Population in 2010," table 1, http://www.census.gov/

population/age/data/2010.html (last viewed 2/14/2013)

9. National Center for Veterans Analysis and Statistics “Veteran Population Projects; FY

2000 to FY 2036;” October 2010, http://www.va.gov/vetdata/docs/QuickFacts/

population_quickfacts.pdf (last viewed 8/30/2012)
CONSUMER FINANCIAL PROTECTION BUREAU

40 CFPB STRATEGIC PLAN FY 2013 - FY 2017

10. Federal Deposit Insurance Corporation, "2011 National Survey of Unbanked and

Underbanked Households," 2012, http://economicinclusion.gov/surveys/

2011household/ (last viewed 2/14/2013)

11. U.S. Department of Commerce, "Income, Poverty, and Health Insurance Coverage in

the United States: 2011," September 2012, http://www.census.gov/prod/2012pubs/

p60-243.pdf (last viewed 2/14/2013)