October 1, 2016 – September 30, 2017

Annual report of the 

Consumer Advisory 

Board
1 CONSUMER FINANCIAL PROTECTION BUREAU 

Letter to the Director from 

Consumer Advisory Board 

Chair and Vice Chair

Richard Cordray, Director 

Consumer Financial Protection Bureau 

1700 G Street, NW

Washington, D.C. 20552

Dear Director Cordray, 

On behalf of the membership of the Consumer Financial Protection Bureau’s (CFPB or Bureau) 

Consumer Advisory Board (CAB or Board), we are honored to present our annual report, which 

details the activities and progress made during the past fiscal year. 

This year marks the fifth anniversary since the CAB’s first inaugural meeting on September 27, 

2012. In that short timeframe, the Board has been busy providing the Bureau with crossindustry expert advice on a variety of consumer financial issues and emerging market trends. 

To achieve our statutory mandate, as outlined in section 1014 of the Dodd–Frank Wall Street 

Reform and Consumer Protection Act, the CAB has met fifteen times in person. In addition, the 

CAB traveled with the Bureau across the country holding public meetings in Missouri, 

California, Mississippi, Nevada, Nebraska, Arkansas, and the District of Columbia. The CAB is 

proud of the role it continues to play in helping the Bureau achieve its mission to protect 

consumers and make consumer financial markets work for everyone.

During the course of this fiscal year, the CAB met in person three times and held twenty 

subcommittee engagements. Through our subcommittees – the Card, Payment, and Deposit 

Markets subcommittee; the Consumer Lending subcommittee; and the Mortgages and Small 

Business Lending Markets subcommittee – members have continued to engage meaningfully 

with Bureau staff at in-person meetings and on conference calls. In these engagements, we 

provided our individual perspectives on the ongoing work of the CFPB. 
2 CONSUMER FINANCIAL PROTECTION BUREAU 

Our subcommittees focused on identifying key observations and principles for regulation on a 

range of topics, such as the Bureau’s debt collection Small Business Regulatory Enforcement 

Fairness Act (SBREFA) proposals, the housing counseling industry, overdraft protection, 

consumer focused shopping tools, consumer reporting and the use of alternative data, reverse 

mortgage servicing practices, loss mitigation efforts, student lending, improving consumer 

access to checking accounts, small business lending, and auto lending. As Chair and Vice Chair 

we worked closely with both the subcommittee Chairs and CAB members directly to ensure that 

the focus of all of our discussions – subcommittee and full CAB meetings – reflected Board 

member interests and issues relevant to the Bureau’s agenda. 

In addition to the CAB’s formal meetings, this year Board members also continued to add value 

to the Bureau’s field work by hosting the CFPB at events across the country; notably, members 

were pleased to host the Bureau for a town hall meeting in Dallas, Texas, as well as host Bureau 

staff for an alternative data and financial empowerment roundtable in San Francisco, California.

In accordance with the Federal Advisory Committee Act (FACA) regulations, this annual report 

provides greater detail about the CAB’s subcommittee discussions, as the larger CAB’s 

discussions were open to the public and are reflected in summaries posted to 

consumerfinance.gov. 

Thank you for the opportunity to serve consumers through the CAB. We look forward to the 

coming year and continuing to fulfill our shared mission of protecting consumers in the 

financial marketplace. 

Sincerely, 

 

Maeve Elise Brown, Chair Ann Baddour, Vice Chair
3 CONSUMER FINANCIAL PROTECTION BUREAU 

Table of contents

Letter to Director from CAB Chair and Vice Chair ................................................1

Table of contents.................................................................................................. 3

1. Executive Summary.............................................................................................................. 4

2. Role of the Consumer Advisory Board ................................................................................. 6

3. Subcommittees ......................................................................................................................7

4. Conclusion ......................................................................................................19

Appendix A: ....................................................................................................... 20

Consumer Advisory Board Biographies .................................................................... 20

Appendix B: ........................................................................................................27

Consumer Advisory Board written statements ..........................................................27
4 CONSUMER FINANCIAL PROTECTION BUREAU 

1. Executive summary 

The Consumer Financial Protection Bureau (CFPB or Bureau) is the nation’s first federal agency 

focused solely on consumer financial protection.1The Dodd-Frank Wall Street Reform and 

Consumer Protection Act (Dodd-Frank Act) created the CFPB to protect consumers of financial 

products and services and to encourage the fair and competitive operation of consumer financial 

markets. 

The CFPB’s Consumer Advisory Board (“CAB” or “Board”) is authorized by §1014(a) of the 

Dodd-Frank Act and was established in September 2012. The statutory purpose of the CAB is 

“to advise and consult with the Bureau in the exercise of its functions under the Federal 

consumer financial laws, and to provide information on emerging practices in the consumer 

financial products or services industry, including regional trends, concerns, and other relevant 

information.”2

In fulfillment of the requirements under the Federal Advisory Committee Act (FACA), the CAB

is pleased to present its Annual Report to the Director. This report primarily summarizes the 

activities and progress of the Board’s subcommittee meetings held over the prior fiscal year, 

October 1, 2016 to September 30, 2017. The discussion portion of this report is divided into 

sections aligned with the CAB’s statutory responsibilities, and the report also includes, in 

Appendix B, separate written statements submitted by Board members relating to the report. 

In this last reporting year, the CAB:

 Held three meetings – October 2016, March 2017, and June 2017 all in Washington, D.C. 

 Organized three policy subcommittees, which have met approximately 20 times: 

o Cards, Payments, and Deposits Subcommittee;

o Consumer Lending Subcommittee; and

o Mortgages and Small Business Lending Subcommittee.

 

1 Previously, seven different federal agencies were responsible for rulemaking, supervision, and enforcement relating 

to consumer financial protection. The agencies which previously administered statutes transferred to the Bureau are 

the Board of Governors of the Federal Reserve System (Federal Reserve, Federal Reserve Board, or Federal Reserve 

Board System), Department of Housing and Urban Development (HUD), Federal Deposit Insurance Corporation 

(FDIC), Federal Trade Commission (FTC), National Credit Union Administration (NCUA), Office of the Comptroller 

of the Currency (OCC), and Office of Thrift Supervision (OTS). 

2 Dodd-Frank Act, Pub. L. No. 111-203, § 1014(a). 
5 CONSUMER FINANCIAL PROTECTION BUREAU 

 Examined and discussed a variety of topics and issues including:

o Trends and themes in financial services and technology;

o Home Mortgage Disclosure Act database and rulemaking;

o Alternative data;

o Seen and heard in the housing market;

o Arbitration; 

o FOIA and ethics review;

o Access to credit and foreclosure issues;

o Future of loss mitigation;

o Housing Counseling; 

o Consumer complaints;

o Overdraft; 

o Payment networks;

o Data aggregators;

o CFPB’s debt collection SBREFA proposals;

o Consumer reporting;

o Student lending;

o Auto lending;

o Reverse mortgages;

o Mortgage servicing;

o Small business lending; and

o Alternative mortgages products

Detailed summaries of the above topics discussed during full Board meetings can be found at 

consumerfinance.gov/about-us/advisorygroups/consumer-advisory-board/.

Members of the CAB and CFPB staff pose for a group photo with Director Cordray before the October 2016

meeting in Washington, D.C. 
6 CONSUMER FINANCIAL PROTECTION BUREAU 

2. Role of the Consumer 

Advisory Board 

Section 1014(a) of the Dodd-Frank Act states: 

The Director shall establish a Consumer Advisory Board to advise and consult with the Bureau in the 

exercise of its functions under the Federal consumer financial laws, and to provide information on 

emerging practices in the consumer financial products or services industry, including regional trends, 

concerns, and other relevant information.

The CAB provides feedback on a range of topics, including consumer engagement, policy 

development, and research, from a range of external stakeholders including academics, industry

participants, community members, and consumer advocates. The CAB consults on a variety of 

cross-cutting topics, reports on meetings, and provides minutes and/or summaries of its

meetings. Members of the Bureau’s Board serve for limited, specified terms. 

Consumer Advisory Board (CAB) member, Chi Chi Wu speaking during the June 2017 CAB meeting in 

Washington, D.C. 
7 CONSUMER FINANCIAL PROTECTION BUREAU 

3. Subcommittees 

Based on the success of the previous years’ CAB subcommittees, the CAB again organized 

subcommittees in consultation with the Bureau, as authorized by section 13 of its charter. As 

provided in the charter, subcommittees report to the Board (not directly to the Bureau) and may 

include participants who are members of the Board or staff of the Bureau. Subcommittees may, 

from time to time, call on individuals who are not members of the Board or staff of the Bureau, 

for the sole purpose of providing specific domain expertise and knowledge.

Each subcommittee is led by a subcommittee Chairperson who is appointed and may be 

removed by the Chairperson of the Board. Meetings of the Board’s subcommittees are called by 

the subcommittee Chairperson and are conducted via teleconference unless the Bureau’s staff 

and subcommittee Chairperson determine that an in-person meeting is necessary.

In January 2016, each subcommittee chair led a process to identify subcommittee priorities, 

including recognizing issues about which subcommittee members wished to learn more, 

identifying and highlighting trends, and raising issues of concern. The reporting year’s priorities 

are outlined below.

 Cards, Payments, and Deposit Markets

The Cards, Payments, and Deposit Markets subcommittee focused on work relating to

overdraft, payment networks, data aggregators, and Fin Tech (financial technology).

 Consumer Lending

The Consumer Lending subcommittee focused on work relating to the Bureau’s Debt 

Collection SBREFA proposals, consumer reporting, alternative data, student lending, 

and auto lending.

 Mortgages and Small Business Lending Markets

The Mortgages and Small Business Lending Markets subcommittee focused on work 

relating to access to credit, reverse mortgages, foreclosure issues, mortgage servicing, 

small business lending, housing counseling dialogues, and alternative mortgage 

products.
8 CONSUMER FINANCIAL PROTECTION BUREAU 

Over the course of the year, all of the subcommittees made progress on their agendas. What 

follows are summaries of the reporting year’s CAB subcommittees’ work. 

Cards, Payments, and Deposit Markets Subcommittee

The Cards, Payments, and Deposit Markets Subcommittee met seven times between October 1, 

2016 and September 30, 2017, three times in person as part of CAB meetings and four times by 

phone. During this timeframe, the subcommittee discussed important topics in the consumer 

financial marketplace such as overdraft, payment networks, data aggregators, and Fin Tech 

(financial technology).

From October 2016 to January 2017, the subcommittee spent three meetings focused on agenda 

setting as well as receiving a briefing from the Bureau on the Federal Reserve Board’s task force 

on secure payments. The subcommittee also discussed overdraft practices across the industry. 

Members shared how it can be difficult to create a comparison shopping tool for overdraft as a 

product because of the variations in the product offerings. Standardization in the product could 

be important because it may provide the opportunity for consumers to make meaningful 

comparisons. 

Additionally, members discussed how checking account providers can make terms and 

conditions more user-friendly. Members also shared how a credit-scoring model would be 

needed to score a checking account, similar to how mortgage tools exist that provide consumers 

Consumer Advisory Board Subcommittee Meetings

[This table includes in-person meetings]

Cards, Payments, and 

Deposit Markets Consumer Lending Mortgages and Small Business Lending Markets

October 26, 2016 October 26, 2016 October 26, 2016

December 12, 2016 November 15, 2016 November 10, 2016

January 31, 2017 February 2, 2017 February 7, 2017

March 1, 2017 March 1, 2017 March 1, 2017

April 4, 2017 April 20, 2017 April 11, 2017

June 7, 2017 June 7, 2017 June 7, 2017

September 14, 2017 September 19, 2017
9 CONSUMER FINANCIAL PROTECTION BUREAU 

a broad picture of options for consumers in similar situations. During the March 2017 in person

meeting, members received an overview on the Bureau’s research on checking and prepaid 

accounts. Bureau staff noted that they discovered issues with opening accounts, product and 

rate variances, and inability to access the banking system. The Bureau has addressed these 

issues by encouraging financial institutions to meet the account access needs of consumers and 

developing tools around selecting and maintaining an account. Members noted that prepaid 

accounts could be a good option for consumers who have had negative experiences with 

overdraft fees. Some members mentioned the development and availability of entry products. 

Members inquired about banks creating checking accounts with an attached credit vehicle. 

In April 2017, the subcommittee met via conference call. The call was a continuation of the prior

in person meeting. Members developed recommendations on how to help low to moderate

income (LMI) consumers get a checking account that is right for them. The subcommittee also 

discussed data aggregators and data availability and were joined by staff from the Office of 

Financial Empowerment. 

During the June 2017 in person meeting, the subcommittee continued an earlier discussion on 

consumer access to information and also discussed risk and potential solutions for data 

aggregators. Bureau staff gave insight on the types of aggregators and the interdependency 

between financial institutions and aggregators. Members discussed the importance of privacy 

and data security. Additionally, members and staff discussed the revised Payment Services 

Directive (PSD2). Some members felt addressing regulatory ambiguities should be a high 

priority. Members noted that competition between banks is good for services. There was 

discussion around the need for consumer control over data. Members and staff also discussed 

the Fair Credit Reporting Act (FCRA) and members asked for clarification on the scope of DoddFrank Section 1033. Additionally, members and staff discussed the technology differences 

between large and small financial institutions as well as the diminishing use of cash. 
10 CONSUMER FINANCIAL PROTECTION BUREAU 

Consumer Lending Subcommittee

The Consumer Lending subcommittee met 7 times between October 1, 2016 and September 30, 

2017, three in person as part of CAB meetings and four times by phone. During this timeframe, 

the subcommittee discussed important topics in the consumer financial marketplace such as the 

Bureau’s Debt Collection SBREFA proposals, consumer reporting, alternative data, student 

lending, and auto lending. 

From October 2016 to January 2017, the subcommittee held two meetings. During the first 

meeting, members welcomed newly appointed CAB members to the subcommittee and spent 

time planning which topics they might want to discuss in the coming year. Members also 

received an introduction to the Bureau’s Consumer Reporting Program Manager and received 

an overview about the position’s role and function. During the second meeting, members 

discussed the Bureau’s debt collection SBREFA proposals. Bureau staff provided a detailed 

briefing on the contents of the proposals and then subcommittee members provided feedback. 

In general, members seemed to agree that regulations for both first-party and third-party debt 

collection are needed to help improve the marketplace. Some members raised concerns that the 

requirements within the proposals for substantiation of the debt are not strong enough to hold 

many third-party debt collectors accountable. While other members argued that substantiation 

requirements need to also be strict for first parties, those members noted that first parties 

should be held accountable for the accuracy of the data that they sell to third party collectors. 

Additionally, some members expressed concern about the Bureau limiting the number of times 

a consumer may be contacted by a debt collector. Those members noted that as the Bureau sets 

up barriers to communication, the likelihood of lawsuits will increase because the debt collector 

will have less opportunity to communicate with the consumer. However, other members 

praised the Bureau for this aspect of the proposals and stated that the proposed limits are 

already very generous, even more so when it is considered that these contacts are limited to a 

per account basis. Members noted the CFPB’s research citing that many consumers already feel 

that they are being contacted too frequently by collectors and that this limitation on the 

frequency of contacts will overall provide a benefit to the consumer. Finally, members also 

stated that the Bureau should do more to address how both first- and third-party collectors may 

communicate using updated technology with a consumer. Members cited the need for this type 

of clarification because the Fair Debt Collections Practices Act (FDCPA) is a dated piece of 

legislation and both industry and consumer advocates would welcome updated and clear rules of 

the road for the marketplace. 
11 CONSUMER FINANCIAL PROTECTION BUREAU 

At the subcommittee’s February 2017 meeting, members discussed consumer reporting and how 

the use of alternative data for underwriting might impact the marketplace. Members 

encouraged the Bureau to consider the costs and benefits around encouraging the use of certain 

types of alternative data. For example, while mobile phone payments might help certain credit 

invisible consumers obtain credit scores, it may also generate negative scores for those same 

consumers. Members noted that consumers often order how they pay their bills each month 

based on how they perceive that particular bill will impact their credit score. Often times, the 

consumer’s understanding or assumption on the bill’s impact may not be accurate. Members 

suggested that the Bureau do more to encourage the consumer reporting marketplace to help 

provide clarity and education to consumers about how scoring models work. Additionally, 

members seemed to agree that whatever new alternative data points are utilized in credit 

scoring models, consumers should have the ability to dispute those new data points in the same 

manner as existing data. Some members noted that the three major Credit Reporting Agencies 

(CRAs) have access to all of the negative data they need about a consumer’s credit history. 

However, most lenders are more interested in seeing the positive credit history when they are 

seeking to lend to a consumer. The Bureau should look for ways to encourage furnishers to find 

ways to furnish positive consumer data to the CRAs. For example, rental payments may prove 

to be predictive, but many landlords only furnish when the consumer has missed a payment 

instead of reporting on the many months of potentially positive payment history 

From March 2017 to April 2017, the subcommittee spent two meetings focused on issues in the 

student lending marketplace. During the first meeting, members heard from the Bureau’s 

Student Lending Program Manager. In the second meeting, members provided feedback to the 

Bureau on the student lending marketplace. A number of members agreed that there are 

parallels between issues in the student lending marketplace and what was occurring in the 

mortgage market in the lead-up to the financial crisis. Members shared on the ground examples 

of continued servicing problems, mostly around consumers attempting to enroll in one of the 

income-based repayment (IBR) options. Some members shared that one option to address IBR 

enrollment would be to have a system where the consumer is automatically enrolled into an IBR 

option upon graduating. Members noted studies that have been done in retirement programs 

where a consumer has to “opt out” versus “opt in” into their 401K program. The results 

regularly show higher rates of enrollment. Members applauded the Bureau for its work to 

educate consumers about student loans and encouraged additional work to be done. Members 

noted that the Bureau should consider training high school counselors to ensure they are aware 
12 CONSUMER FINANCIAL PROTECTION BUREAU 

of existing CFPB resources as well as providing targeted educational information to consumers 

who contact the Bureau through its Consumer Complaint Portal. 

At the subcommittee’s June 2017 meeting, members discussed two Bureau activities around the 

consumer reporting marketplace. The first discussion was on the open score marketplace and 

how the Bureau’s efforts to promote consumer access to free credit scores might be shaping the 

market. Some members noted that more resources should be devoted by the Bureau to help 

educate consumers around the consumer reporting marketplace and their credit score. 

Members stated that it may be helpful for the Bureau to modify its educational resources for 

consumers who are subprime, prime, and super prime. Other members suggested the Bureau 

encourage companies participating in the open score initiative to be sure they provide a link to 

AnnualCreditReport.com on every free score they provide to a consumer. That could help 

address some consumer confusion should they see a lower credit score than they may have 

expected. Members also encouraged the Bureau to study how consumers are utilizing their free 

credit score and how their behaviors might have changed due to this added information. The 

second discussion was on the Office of Financial Empowerment’s credit building strategy. 

Members applauded the Bureau for its work on this issue and noted that there may be some 

products that aren’t beneficial at the moment for consumers who are trying to build their credit. 

For example, a few members highlighted that some large financial institutions do not offer

secured credit cards because there is no money to be made from the product. These types of 

cards have high administrative costs and are not typically used as a starter product. Members 

noted that the larger financial institutions have gone the route of using alternative data instead 

of credit building products to try to solve for consumers with either no or low credit scores. 

Other members suggested that the Bureau work with industry to find ways where a consumer 

could utilize a secured card without securitizing it with cash. 

Finally, in September 2017, the subcommittee had its final meeting of the fiscal year. Members 

discussed current issues in the auto lending marketplace and then wrapped up their work. 

Subcommittee members shared their thoughts about the year’s work and ended the meeting 

with appreciations for the service of those subcommittee members with expiring CAB terms. In 

regard to the auto lending marketplace discussion, members noted that they continue to see 

auto loans for vehicles under $10,000 where the consumer is frequently upside down on the 

loan. Additionally, a member stated that in her region of the country she regularly comes across 

loans where the loan-to-value (LTV) is 140%. Some members highlighted that there continue to 

be issues around the types and cost of add-on products being sold at the dealership as well as if 

an ability to repay (ATR) assessment is even conducted. Members noted that they have begun to 
13 CONSUMER FINANCIAL PROTECTION BUREAU 

see gap insurance products that do not actually cover the full difference between the loan 

amount and the value of the vehicle. This could cause issues for consumers in portions of the 

country that have been impacted by recent hurricanes and have had their vehicles totaled. 

Additionally, several members stated that there is a continued need by the Bureau and other 

regulatory bodies to study and take action as needed in regard to disparate impact in the auto 

lending marketplace. Those members noted that they have seen communities of color receive 

higher interest rates on auto loans when compared to white borrowers. There may also be 

disparities in lending for women versus male borrowers. Members encouraged the Bureau to 

continue to pursue actions against lenders who engage in this type of practice. 
14 CONSUMER FINANCIAL PROTECTION BUREAU 

Mortgages and Small Business Lending Markets 

Subcommittee

The Mortgages and Small Business Lending Markets Subcommittee met seven times between 

October 2016 and September 2017, three in person as part of CAB meetings and four times via

conference calls. During this timeframe, the subcommittee discussed important topics in the 

residential mortgage marketplace and small business lending markets such as: access to credit, 

reverse mortgages, foreclosure issues, mortgage servicing, small business lending, housing 

counseling dialogues and alternative mortgage products.

From October 2016 to January 2017, the subcommittee focused primarily on housing counselor 

conversations and small business lending. During these engagements, members highlighted that 

the state of housing is much stronger; eight years after the mortgage foreclosure crisis, there are 

fewer foreclosures in most metropolitan statistical areas. Members emphasized that there are 

still some pockets with high foreclosure activity and the Bureau should monitor this activity. A 

member expressed some concerns regarding the potential repercussions once the Making Home 

Affordable program expires. Subcommittee members suggested the Bureau should continue to 

work with other federal agencies and ensure that there is continuity on current 

borrower/servicer engagement activities. Housing counseling in the loss mitigation space has 

been decreasing over the past 2 years; however, housing counseling in the origination space is 

increasing and has lots of effective counseling potential. 

Subcommittee members suggested the Bureau should provide more clarity in the fee for service 

space, since housing counselors would like to participate in pre-purchase counseling sessions. 

Members reported counselors need direction to ensure that industry and advocates are 

complying with RESPA’s Section 8. Before the Bureau was created, HUD allowed advocates to 

receive industry compensation for services provided without fear of RESPA violations. Members 

also reported that the PHH case has created more anxiety and confusion among interested 

stakeholders. Housing counselors requested pro-bono counsel who could interpret RESPA and 

requested more clarity from the CFPB; the ultimate goal is to continue providing quality prepurchase housing counseling advice to these consumers and ensure that all stakeholders comply 

with RESPA. 
15 CONSUMER FINANCIAL PROTECTION BUREAU 

Members praised the Bureau’s focus on small business lending data tracking and expect that 

this new office will be extremely beneficial in helping understand how these markets operate. 

The CAB would like to emphasize the importance of this new office, as it will ensure that there is 

adequate access to credit in these low to moderate income communities as it relates to accessing 

small business loans, recognizing that many “small businesses” are self-employed consumers. 

Members suggested that when the Bureau implements the Dodd-Frank Act’s Section 1071 the 

small business lending data should be segregated by race, ethnicity and gender, similar to 

HMDA data segregation. Due to the lack of small business lending data, some banks, upon 

request by interested stakeholders, do provide census track and surname information for 

tracking purposes; however, not all banks provide this information.

From February 2017 to April 2017, the subcommittee continued to focus on housing counselor 

challenges, access to credit, and reverse mortgages. During the housing counselor discussions, 

members highlighted that housing counselors are still having conversations with Bureau 

partners regarding fee for service models. Housing counselors provided sample fee for-service 

contracts to the Bureau, as the industry and housing counselors alike would like more clarity 

regarding the legality of these arrangements. The MBA, NAHREP and other national trade 

groups drafted a letter to Congress in which they highlight the importance of housing counselors 

and request Congress to fund these entities with $55 million for fiscal year 2017. These funds 

will provide support for housing counselors in the origination space and foreclosure prevention 

areas. Housing counseling in the loss mitigation space has been decreasing over the past 2 years; 

however, housing counseling in the origination space is increasing and has lots of counseling 

potential.

During the access to credit discussions, subcommittee members reminded the Bureau that some 

major lenders with great regional market share are not lending to communities of color and this

is negatively impacting these communities. Subcommittee members noted that mortgage 

availability in the Jumbo markets has not been impacted by the current regulatory environment. 

Banks are having no problem in qualifying consumers for home loans; the issue is availability of 

real estate residential properties and selective availability of credit for some borrowers. The lack 

of inventory is creating mini- housing bubbles in some markets. In addition, cash buyers are 

buying properties in bulk, leaving low to moderate income families out of the home ownership 
16 CONSUMER FINANCIAL PROTECTION BUREAU 

equation. Subcommittee members emphasized that these situations have been addressed before, 

many years ago, and nothing is happening. It is time to see some proactive action taken, so these 

consumers are able to enter these markets in an affordable way. Members also pointed out that

alternative mortgage arrangements have had a negative impact on those who feel they are not 

eligible for traditional credit. Often times, lack of inventory meets the selective availability of 

credit leading homeowners to purchase substandard homes with subprime credit. 

The subcommittee’s chair provided a high-level overview of questionable practices in the reverse 

mortgage servicing space in the state of Florida. It is apparent that the older American 

community is still being impacted by questionable foreclosure practices. According to the 

subcommittee chair, there are major concerns with some mortgage servicers, as these 

institutions are accelerating the note and foreclosing on these consumers for not providing the 

yearly occupancy notice. There is no requirement on the note, nortgage or deed of trust that, if 

this document is not provided, the servicer can initiate foreclosure. In regard to delinquent tax 

and insurance accounts, the Department of Housing and Urban Development (HUD) has 

indicated that servicers should work with the consumer and find loss mitigation alternatives 

which should avoid further hardship or foreclosure; not all servicers attempt to assist these 

struggling homeowners. HUD must ensure that these vendor communications with consumers 

are more organized, as it is very confusing for these older Americans to communicate with 

different vendors; this should be streamlined. RESPA and new servicing rules have normalized 

servicing to an extent, but many of the rules do not apply to reverse mortgages, specifically the 

loss mitigation rules. The subcommittee chair encourgaged the CFPB to strive to make these 

reverse mortgage servicing companies more accountable.

During the March 2017 in person meeting, members interacted with Research Markets and 

Regulations Staff, engaging in a mortgage servicing, deed contract, and foreclosure conversation. 

In regard to mortgage servicing, members have seen that some non-bank companies are not 

complying 100% with the new CFPB servicing rules, but the largest financial institutions have 

made noticeable improvements in this space. These procedures are extremely important, as they 

protect the most vulnerable consumers who face hardship or foreclosure. 

Members encouraged the Bureau to pay close attention to “zombie foreclosures,” as these may 

have fair housing implications. These foreclosures take place in minority-majority communities 
17 CONSUMER FINANCIAL PROTECTION BUREAU 

and members have also noticed property appreciation differentials compared to other 

communities. 

Members noted that some markets have experienced an uptick in the contract for deed space. 

Some members believe that these contracts are abusive and negatively impact low to moderate 

income consumers. Interest rates and total payments are not disclosed, no TILA cost of credit 

information is provided, homes are substandard and consumers have no recourse option due to 

arbitration clauses. Members encourgaged the Bureau to regulate this market due to the 

abusive practices taking place and the lack of TILA disclosures.

The subcommittee reminded the Bureau that the small business lending marketplace needs 

some reform. Members are hopeful that future work on small business lending data collection 

will provide essential demographic information which is helpful in determining potential 

lending discrimination. Members recommended that the Bureau should reach out to diverse law 

schools and small business clinics, as these groups may provide granular market information

that may be beneficial during the request of information and research stage.

From June 2017 to September 2017, the subcommittee focused on the Bureau’s future work on 

small business lending data collection, access to credit, and reverse mortgages. During the June 

meeting, members reacted to the recent small business lending Bureau white paper and 

provided valuable feedback to staff. Members have concerns regarding the lack of small business 

lending, specifically for those consumers looking to obtain smaller balance loans. It appears to 

some subcommittee members that large banks have no interest in this market sector and that 

must be addressed, as lenders might not be complying with CRA mandates. The subcommittee 

encouraged the CFPB to work with advocates and create new education tools for new small 

business owners, including lending tips (similar to Know Before You Owe in the mortgage 

space). The subcommittee suggested that it would be beneficial to provide consumers tips on 

how to identify legitimate lenders and avoid risky credit options. Members have noticed an 

uptick in online small business lending due to the lack of banking institutions in low to 

moderate income neighborhoods. Those members expect that this will create a “Payday Lender” 

environment and consumers will end up obtaining riskier small business lending products 

online. The subcommittee suggested that the Bureau provide stakeholders a clear definition of 
18 CONSUMER FINANCIAL PROTECTION BUREAU 

what a small business is; there are currently several definitions, and the market would benefit 

from one consistent definition.

During the access to credit conversations, members highlighted that for the past few years, 

housing counselors have noticed that short sales are being coded by credit reporting agencies as 

foreclosures; hence the consumer’s credit profile is negatively impacted for a longer time 

(typically seven years). Due to this incorrect credit reporting, automated underwriting systems 

(AUS) are rejecting these loan applications. This issue has been discussed since 2013 and 

through Congressional action, the coding was modified in order to correct this; however, it 

appears that the issue is still prevalent. If consumers dispute any information on their credit 

reports, the AUS systems will reject the file and underwriters will downgrade it to a manual 

review (unfair to some credit challenged consumers). In addition, the vast majority of these 

manually underwritten loans are not bought by the secondary market. One of the benefits of 

AUS is the fact that it removes subjective criteria and reduces the potential of discrimination. 

Members stated that you can’t underwrite culture; many large banks are not going above and 

beyond when it comes to helping low to moderate income families’ access mortgage credit.

Members commended the Bureau on its recent reverse mortgage Know Before You Owe report. 

The subcommittee supports the Bureau’s initiative regarding these educational and research 

efforts and looks forward to more future collaborations. More work is ahead, as some servicers 

have not been proactive when it comes to allowing consumers to participate in “cash for keys” or 

other loss mitigation efforts. The subcommittee expects that the recent HUD/HECM mortgagee

letter will prompt servicers to provide this option to consumers more consistently. The 

subcommittee believes that the loss mitigation protections on Regulation X do not go far enough 

to protect reverse mortgage consumers and older Americans. The subcommittee recommends 

that the Bureau seriously consider amending Regulation X to include more protections for these 

vulnerable older Americans.
19 CONSUMER FINANCIAL PROTECTION BUREAU 

4. Conclusion

In closing, in its fifth year, the Board has continued to share vital advice, expertise, and technical 

information with the Bureau and its staff. CAB members would like to thank the Consumer 

Financial Protection Bureau for the chance to help further the Bureau’s mission of helping to 

make markets for consumer financial products and services work for Americans. This joint 

report and attached individual remarks are presented in the spirit of cooperation and 

collaboration. 
20 CONSUMER FINANCIAL PROTECTION BUREAU 

APPENDIX A:

Consumer Advisory Board 

Biographies3

Chairperson, Maeve Brown currently serves as Executive Director of the Housing and 

Economic Rights Advocates, an organization that she co-founded in 2005. She has over 28 

years as a public interest attorney, in varies organization in Southern and Northern 

California. She has published articles on affordable housing issues and authored a chapter in 

the American Bar Association's Legal Guide to Affordable Housing Development (first 

edition and updated), is bilingual in Spanish and French and conversant in Japanese, Farsi, 

Italian and German.

Vice Chairperson, Ann Baddour is Director of Fair Financial Services Project at Texas 

Appleseed, a public interest law center, where she has overseen projects aimed at bringing 

low- income and immigrant consumers into the financial mainstream since 1999. She is 

actively involved in reform of regulations governing payday and auto title lending in Texas 

to build greater consumer protection into these transactions. Her work in the areas of 

immigrant financial education and improving consumer disclosure and protection in 

remittance transactions has been instrumental in laying the groundwork for national 

oversight of remittances. She has presented at economic and asset building conferences 

across the United States and in Benin, Mexico, and the European Union. She has been 

recognized for her work by the FDIC and the El Paso Invest in the American Dream 

Initiative. Prior to working for Texas Appleseed, she was a research analyst with the Texas 

Legislative Council.

Seema Agnani is the Director of Policy and Civic Engagement at the National Coalition for 

Asian Pacific Americans Community Development (National CAPACD) – a coalition of more 

than 100 community based organizations, that seeks to improve the lives of over two-million 

Asian Americans and Pacific Islanders who live in poverty in the US by providing voice, 

 

3 Consumer Advisory Board biographies reflect the membership of the CAB between October 1, 2016 and September 

30, 2017. 
21 CONSUMER FINANCIAL PROTECTION BUREAU 

tools, and shared knowledge to drive change. She was a founder and served as Executive 

Director of Chhaya CDC, based in Jackson Heights, Queens – working with thousands of

South Asian and other immigrant groups on housing preservation as well as neighborhood 

and economic justice issues. Previously, she coordinated the Fund for New Citizens at The 

New York Community Trust, led the Training and Technical Assistance program for the 

Citizens Committee for NYC, and developed affordable housing with Asian Americans for 

Equality in New York City. She is also currently a member of the board of directors of South 

Asian Americans Leading Together (SAALT). She is originally from the Chicago metro area, 

where her parents immigrated to the US from India.

Sylvia Alvarez is the founder and Executive Director of the Housing & Education Alliance,

a HUD certified housing counseling agency serving over 45,000 Tampa Bay area residents 

since 2002. She has over 25 years’ experience in real estate, mortgage lending, affordable 

housing and housing counseling. She co-authored “The American Nightmare: Strategies for 

Preventing, Surviving and Overcoming Foreclosure.” The book was endorsed by Freddie 

Mac and the National Association of Hispanic Real Estate Professionals, translated into 

Spanish and used by consumers and HUD housing counselors throughout the country. 

Through her leadership her agency has received much recognition and many awards,

including the coveted "NonProfit of the Year" through PBS's national franchise the Be More 

Awards.

Tim Chen is the CEO of NerdWallet, which he co-founded in 2009. Tim sets the strategic 

vision for NerdWallet and is determined to give consumers clarity around all of life's 

financial decisions. Previously, Tim was a hedge fund analyst at Perry Capital investing in 

payment processing firms, credit card networks and technology companies. He also worked 

as an equity research analyst at Credit Suisse First Boston.

Lynn Drysdale is Managing Attorney of the Consumer Law Unit for Jacksonville Area 

Legal Aid, Inc. Ms. Drysdale is also a member of the National Association of Consumer 

Advocates and has been a contributing writer for the National Consumer Law Center, the 

Consumer Financial Services Law Report, and co-authored The Two-Tiered Consumer 

Financial Services Marketplace: The Fringe Banking System and its Challenge to Current 

Thinking About The Role of Usury Laws in Today's Society, a law review article for the South 

Carolina Law Review, Volume 51, Spring 2000, Number 3 with distinguished consumer 

advocate, Kathleen Keest, Esquire. Ms. Drysdale has been a presenter at the Consumer 

Assembly, the National Consumer Law Center's annual conference, the Practicing Law 

Institute Consumer Financial Services Litigation Training, and the Conference of State Bank 

Supervisors and the 2004 National Association of Consumer Credit Administrators Pay Day 

Lending Regulator Summit.

Kathleen C. Engel is a Research Professor of Law at Suffolk University in Boston. She is a 

national authority on mortgage finance and regulation, subprime and predatory lending, 

consumer credit, and housing discrimination. Her many publications include the coauthored book, The Subprime Virus: Reckless Credit, Regulatory Failure and Next Steps and 

articles in Harvard Business Law Review, Texas Law Review, and Housing Policy Debate. 

Professor Engel presents her award-winning research in academic, banking, and policy 

forums throughout the country and around the world. Professor Engel also regularly advises 

federal and state agencies on various matters related to financing of credit and served for 

three years on the Consumer Advisory Council of the Federal Reserve Board. 
22 CONSUMER FINANCIAL PROTECTION BUREAU 

Judith L. Fox is a Clinical Professor of Law at the Notre Dame Law School, where she 

teaches and practices consumer law. She joined the faculty in 1997 and teaches courses in 

consumer law and negotiation. Ms. Fox directs the Economic Justice Project, a low income 

clinic specializing in foreclosure and debt collection defense. She is a member of the Indiana 

Mortgage Foreclosure Task Force and co-chairs the AALS Clinical Section’s Standing 

Committee on Lawyering in the Public Interest. Prior to attending law school, she was a 

bank manager and loan officer. Ms. Fox has authored a number of publications and issues 

of foreclosure and debt collection.

Paulina Gonzalez serves as Executive Director of the California Reinvestment Coalition 

(CRC), the largest state reinvestment coalition in the country. Under her leadership, CRC 

members have negotiated several multi-billion dollar bank reinvestment 

agreements. Through these commitments, banks increase their focus on meeting the credit 

needs of low-income communities and communities of color by offering affordable housing 

financing, small business lending, and safe, affordable, and transparent financial services 

and products. Prior to her work at CRC, Ms. Gonzalez served as Executive Director of SAJE 

(Strategic Actions for a Just Economy), located in South Central Los Angeles. During her 

tenure, SAJE’s advocacy resulted in groundbreaking, multi-million dollar Community 

Benefit Agreements that provided investments in affordable housing, living wage jobs, small 

business development, and a community health center.

Julie Gugin currently serves as the Executive Director of the Minnesota Homeownership 

Center, a position she has held since 2007. She has over 20 years of non-profit leadership 

experience; previous positions include Vice President of Operations for Twin Cities Habitat 

for Humanity and Director of Supportive Housing at the Wilder Foundation. She is a cofounder of the Framework Homeownership, LLC, a non-profit technology start-up company 

for homebuyer education. She co-chaired the statewide Minnesota Foreclosure Partners 

Council and currently serves on the National Industry Standards (for homeownership 

education and counseling) committee.

Neil F. Hall (Retired) was executive vice president and head of PNC’s Retail Banking. He 

was responsible for leading PNC’s consumer businesses, business banking, brokerage and 

distribution. Prior to being named EVP, he led the delivery of sales and service to PNC’s 

retail and small business customers, directing branch banking, business banking, 

community development and PNC Investments. Hall joined PNC in 1995 and has held 

various positions within retail banking. Prior to joining PNC, he was executive vice president 

of Chemical Bank New Jersey’s Consumer Banking Group. He began his banking career at 

Irving Trust Company and held several positions in commercial and private banking. Hall is 

a former board member of the Consumer Bankers Association.

William Howle, II, is President of U.S. Retail Banking at Citi, where he drives financial, 

client service and operational results with a team of 8,400 employees serving 3.6 million 

consumer households and 264,000 small businesses. Will is guiding the retail bank’s clientled transformation to meet the needs of all customers, delivering on how they want to bank 

now and in the future. He is a highly-seasoned executive with more than 25 years of 

leadership experience in banking, spanning retail, commercial, small business and wealth 

management at Citi, Morgan Stanley, Wachovia and Bank of America. A strong advocate of 

the banking industry, Will regularly meets with regulators and legislators on Capitol Hill on 
23 CONSUMER FINANCIAL PROTECTION BUREAU 

behalf of Citi and the Consumer Bankers Association, which he is chairing from 2015 –

2016.

Brian D. Hughes currently serves as Executive Vice President and Chief Risk Officer for 

Discover Financial Services where he is a member of the Executive Committee. Brian has 

over 20 years of experience serving consumers in financial services and consumer goods and 

has previously worked as Senior Vice President and General Manager of the Discover 

Deposits business, Senior Vice President of Discover Cardmember Marketing, Senior 

Executive Vice President and CEO of HSBC Card and Retail Services, and Principal at the 

management consulting firm Booz-Allen & Hamilton.

Christopher Kukla is Executive Vice President at the Center for Responsible Lending in 

Durham, North Carolina. The Center is a nonpartisan, non-profit policy and research 

affiliate of Self-Help, a community development lender that has provided more than $6 

billion in financing to homeowners, small businesses, and non-profit organizations 

nationwide. Chris leads CRL’s work on auto lending issues and CRL’s policy work in North 

Carolina. He counsels policymakers and advocates on the national and state level on 

consumer lending legislation and regulation. Chris is also Adjunct Professor of Law at the 

University of North Carolina Law School, where he teaches consumer law. Prior to joining 

CRL, Chris served as a Congressional aide for five years, focused primarily on 

appropriations and financial services issues.

Max Levchin is the founder and CEO of Affirm, an online financial services technology 

company. Max was one of the original cofounders of PayPal where he served as the CTO 

until its acquisition by Ebay in 2002. That same year, he was named to the MIT Technology 

Review TR100 as one of the top 100 innovators in the world under the age of 35, as well as 

Innovator of the Year. He has served on the boards of Yahoo!, Evernote and Yelp, is an 

active investor in and advisor to several payments, bitcoin, collections, remittance, 

marketplace lending platforms, fraud detection and prevention technology startups. Max is 

a serial entrepreneur, computer scientist, philanthropist and active investor in early stage 

startups.

Brian Longe currently serves as CEO of AST Group whose companies include American 

Stock Transfer and Trust, CST Trust Company, Donlin Recano & Company, Inc., LINK 

Shareholder Services and D.F. King. Previously to this position, Brian served as CEO of 

Wolters Kluwer Financial & Compliance Services Division from 2010-2015. From 2005-

2010 he served as President and CEO of Wolters Kluwer Financial Services. Prior to joining 

Wolters Kluwer in 2005, Brian held numerous leadership positions in companies that 

specialize in developing information technology and solutions. Brian also serves on the 

national board of directors for Operation HOPE, a non- profit organization dedicated to 

financial literacy and empowerment.

Ruhi Maker is a senior staff attorney in Empire Justice Center's Rochester office. She has 

been a public interest attorney for over 30 years, working on fair lending, access to credit, 

affordable housing and community reinvestment issues. Ms. Maker co-convened the Greater 

Rochester Community Reinvestment Coalition (GRCRC) in 1993. Since then, GRCRC has 

released 15 home mortgage, small business and subprime lending analyses and submitted 

dozens of CRA exam and bank merger comments. Ms. Maker served on the Federal Reserve 

Board's Consumer Advisory Council from 2002-2004.
24 CONSUMER FINANCIAL PROTECTION BUREAU 

Joann Needleman is a partner at Clark Hill PLC and leader of Clark Hill’s Consumer 

Financial Services Regulatory & Compliance group. Joann has extensive litigation 

experience in state and federal courts, successfully defending creditors against claims 

brought under the Fair Debt Collection Practices Act and Fair Credit Reporting Act as well 

as state statutes. She provides counsel, consultation and litigation services to financial 

institutions, law firms and debt buyers throughout the country. Joann is the current 

President of the Board of Directors of the National Creditors Bar Association.

J. Patrick O’Shaughnessy currently serves as the head of U.S. operations for Grupo Elektra, 

a leading Latin American financial services provider and part of the Grupo Salinas family of 

companies. He is President and CEO of Advance America, which he led prior to its merger with 

Grupo Elektra. Before joining Advance America, Patrick worked in the investment banking 

industry in New York. He spent most of his investment banking career at Donaldson, Lufkin & 

Jenrette (DLJ) and with Credit Suisse, after its acquisition of DLJ. He also worked for Kidder, 

Peabody and Thomas Weisel Partners. Patrick is the Chairman of the Board of the Community 

Financial Services Association of America, an industry trade group that advocates for consumer 

access to regulated financial services. He is an Aspen Institute Fellow and a member of the 

Board of Trustees of Converse College. He was graduated from the University of Notre Dame 

and received his MBA from the University of Chicago’s Booth School of Business.

Paheadra Bratton Robinson currently serves as the Executive Director of the Coalition 

for a Prosperous Mississippi. Paheadra has been addressing civil rights and consumer 

protection issues for more than 10 years. She is currently a member of the Federal Deposit 

Insurance Corporation (FDIC) Alliance of Economic Inclusion, has served as a member of 

the steering committee for the Delta State University Center for Community and Economic 

Development, is a past board member for the Mississippi Community and Financial Access 

Coalition. In addition to private practice, Paheadra has served as legislative counsel in the 

Mississippi House of Representatives.

Arjan Schütte is the founder and a managing partner of Core Innovation Capital, a leading 

venture capital fund investing in financial services companies that empower everyday 

Americans. He is a passionate advocate for market-based financial inclusion, and invests in 

pro-consumer businesses bringing this mission to scale. Arjan is a Senior Advisor to the 

Center for Financial Services Innovation (CFSI), the nation’s leading authority on financial 

health, which he helped start in 2004. Arjan earned his Master’s from the Media Laboratory 

at the Massachusetts Institute of Technology, as an Interval Research Fellow, and his 

Bachelor’s in Philosophy and Communication at Lewis & Clark College.

Lisa J. Servon is Professor of City and Regional Planning at the University of 

Pennsylvania. Prior to joining the University of Pennsylvania, she was Professor of 

Management and Urban Policy at The New School, where she also served as dean. Professor 

Servon holds a PhD in Urban Planning from the University of California, Berkeley, an MA in

the History of Art from the University of Pennsylvania and a BA from Bryn Mawr College. 

She teaches and conducts research in the areas of urban poverty, community development, 

economic development, and issues of gender and race. Her current research focuses on the 

alternative financial services industry. Her book The Unbanking of America: How the New 

Middle Class Survives, for which she worked as a teller at a check casher and at a payday 

lender, was published by Houghton Mifflin Harcourt in January 2017. Servon spent 2015-
25 CONSUMER FINANCIAL PROTECTION BUREAU 

2016 as a scholar at the Russell Sage Foundation. She spent 2004-2005 as Senior Research 

Fellow at the New America Foundation in Washington, DC. 

Gene Spencer currently serves as the senior vice president for stakeholder engagement, 

policy and research at the Homeownership Preservation Foundation (HPF), in Washington, 

DC, a position he has held since 2010. HPF operates the Homeowner’s Hope Hotline, which 

provides financial education and foreclosure prevention counseling to consumers 

nationwide and is the national call to action for the US government’s Making Home 

Affordable Program. Previously, Mr. Spencer served as a public affairs director at BursonMarsteller and in several positions at Fannie Mae during a 28-year career, including 

executive positions in investor relations and mortgage securitization.

James (Jim) Van Dyke is CEO and founder of Futurion.digital, providing advisory 

services on mobile and digital commerce, payments, financial technology (fintech), identity 

and security. His 32 years of experience in end-user focused innovation includes founding 

and leading Javelin Strategy & Research as well as leadership roles in other research and 

strategy firms. Mr. Van Dyke has also held fintech, digital commerce and security product 

management roles within firms, ranging from startup to Fortune 500. Jim is also a frequent 

presenter at futurist or thought-leadership events.

Raul Vazquez is CEO of Oportun, a mission-driven Community Development Financial 

Institution (CDFI) that uses advanced data analytics and technology to provide affordable 

loans to Latinos and others with little or no credit history so they can establish credit and 

build a better future. Oportun has helped more than 770,000 customers by disbursing more 

than $2.6 billion in small dollar loans through its 200+ locations across six states. Prior to 

joining Oportun, he spent nine years at Walmart in various senior leadership roles, worked 

in e-commerce start-ups, and was also a consultant and industrial engineer. Raul is a 

member of the Federal Reserve Board’s Community Advisory Council and serves as its 

Chair. He also serves on the board of directors of Intuit. He has a B.S. and M.S. in Industrial 

Engineering from Stanford and an M.B.A. from the Wharton Business School at the 

University of Pennsylvania.

James M. Wehmann is executive vice president of FICO’s Scores business unit, a position 

held since 2012. He leads all aspects of the global FICO Score business, including its use in 

risk management and its distribution to consumers through various channels. His work 

includes global initiatives designed to positively impact consumer financial inclusion and 

consumer financial education. At FICO, Jim has developed deep insights into consumer 

credit trends and reporting practices, which he routinely shares with a broad group of 

stakeholders. Prior to FICO, much of Jim’s twenty-five year career has focused on consumer 

marketing, including financial products, where he studied consumer behavior and 

developed communication strategies designed to influence consumer attitudes and actions. 

Chi Chi Wu has been a staff attorney at National Consumer Law Center since 2001. Chi Chi 

focuses on consumer credit issues at NCLC, including legislative, administrative, and other 

advocacy. Chi Chi's specialties include fair credit reporting, credit cards, refund anticipation 

loans, and medical debt. Chi Chi frequently serves as a resource for policymakers and the 

media on consumer credit issues. Before joining NCLC, Chi Chi worked in the Consumer 

Protection Division at the Massachusetts Attorney General's office and the Asian Outreach 

Unit of Greater Boston Legal Services.. Chi Chi is co-author of the legal manuals Fair Credit 
26 CONSUMER FINANCIAL PROTECTION BUREAU 

Reporting Act and Collection Actions, and a contributing author to Consumer Credit 

Regulation and Truth in Lending.

Josh Zinner is the Chief Executive Officer of the Interfaith Center on Corporate 

Responsibility, a leading coalition of progressive shareholders pressing for corporate 

accountability and economic, social and environmental justice. He was previously the CoDirector of New Economy Project, an advocacy organization that works with community 

groups to promote racial and economic justice in New York City neighborhoods. In this role, 

he was instrumental in winning passage of groundbreaking legislation and regulations to 

curb financial abuses in New York City and State. Prior to that, he was the founding director 

of the Foreclosure Prevention Project at South Brooklyn Legal Services, where he litigated 

lending and foreclosure cases in federal and state court, and was an early national voice 

against predatory lending. He was a founding member of New Yorkers for Responsible 

Lending, a prominent statewide financial justice coalition, and has trained numerous 

attorneys and advocates in New York City and State, and around the country.
27 CONSUMER FINANCIAL PROTECTION BUREAU 

APPENDIX B:

Consumer Advisory Board 

written statements

The following statements were submitted by CAB members: 
The Honorable Richard Cordray 

Director, Consumer Financial Protection Bureau

1700 G Street Northwest

Washington, D.C., 20552

August 28, 2017

Dear Director Cordray,

Thank you for the opportunity to share my experiences serving on the CFPB Consumer Advisory 

Board (CAB). As I move into my fourth and final year on the CAB as the incoming chair, I hope 

to build on the vision and achievements of the leaders who have come before me. I look forward 

to continuing our efforts to offer the CFPB guidance on how financial policies and practices 

impact family financial well-being, and to work together towards a financial services system that 

enables our communities and our markets to thrive together. 

I have had the honor to serve on the CAB in many different capacities—as a general member, 

chair of the small-dollar lending committee, vice-chair of the CAB, and now, in the upcoming 

year, as chair of the CAB. The year I chaired the small-dollar lending committee was 

particularly meaningful to me, as I was able to engage in the committee public input process for 

the very important proposed small-dollar lending rule. I have seen firsthand many of the 

financial harms caused by payday and auto title lending in my home state of Texas. I 

appreciated being a part of a thoughtful and deliberative process that pulled in a broad range of 

interests and perspectives. If a final rule is adopted and implemented, I am hopeful that the 

results of this inclusive rulemaking process will make important and desperately needed strides 

towards a fair playing field in a market that has been rife with abuse for decades. 

Looking back on three years as a member of the CAB, I have been impressed consistently by the 

technical expertise and thoughtfulness of CFPB staff and by the quality of the analyses and 

resources that the agency produces. 

The holistic view of consumer financial protection that drives the agency work and vision 

underpins the tremendous positive impacts of the CFPB on families across our country. The 

CFPB has returned around $12 billion to the pockets of individuals cheated by financial services 
providers. It has empowered individuals through its complaints database, financial education 

resources, and cutting-edge research into the drivers of and barriers to family financial wellbeing. The CFPB has engaged in important enforcement actions to ensure that profit incentives 

in the market are tied to complying with the law, and it has engaged in key rulemakings to fix 

areas where our markets are broken.

I also value deeply the opportunity to learn from my peers on the CAB who cover a spectrum of 

stakeholders, including consumer policy experts, academics, industry representatives, fintech 

experts and direct service providers. Together, we have been able to offer new insights to the 

CFPB and ensure the agency work remains relevant in the face of evolving community 

experiences and market practices.

We have seen a lot of important progress through the six-year track record of the CFPB, but 

much work remains. Though memories of the Great Recession may be fading for some, the 

financial wounds, particularly for low- and moderate-income families, are far from healed.

The current natural disaster caused by Hurricane Harvey, which is impacting millions of 

Texans—including my family, my friends, and my broader community—brings home the 

fragility that exists in all of our lives and our financial lives. It means so much to me and to 

millions of Americans that when it comes to consumer financial protection, the CFPB has our 

backs.

Sincerely,

Ann Baddour

Director, Fair Financial Services Program

Texas Appleseed
corevc.com	|	1680	Vine	Street,	Suite	606	|	Los	Angeles,	CA	90028

September 14, 2017

Dear Director Cordray: 

I’m grateful to have been able to serve on the CFPB’s Consumer Advisory Board (CAB) this 

past year, and I’m glad to share some reflections on my experience to date: on existing CFPB 

initiatives, on areas I believe could benefit from more attention and on the CAB itself.

On existing initiatives. I’m particularly excited about the CFPB’s impact potential on open data 

access (1033), alternative credit data, small business, expanding the financial empowerment, and 

encourage the Bureau to double down on these efforts. Here’s why:

The opportunity for “bank aggregators” (e.g. Plaid, Yodlee) to democratize financial services 

and align consumers’ interests with financial products is profound and I hope the Bureau will 

exhibit industry leadership to protect these data outside the walls of banks (which would prefer 

to keep the data inside). 

Alternative and “big” data, similarly, hold the keys to emancipate millions of Americans outside 

and on the fringes of the financial system to better, cheaper access to all consumer financial (and 

insurance) products. The Bureau can lead the industry to modernize Fair Lending (and related) 

practices for a data-driven future. 

I’m a firm supporter of the Bureau’s nascent work on small business, on the dual premise that 

almost all small businesses are sole proprietorships, but with zero protections, and because small 

business is so important to both household- and national GDP. I’d love to see the Bureau double 

down its efforts, in concert with progressive actors (e.g. PayPal and Intuit). 

I’ve enjoyed working with Daniel Dodd-Ramirez’s team in Financial Empowerment, who have 

been eager to think outside the box of their expertise to explore partnership opportunities within 

the for-profit industry. I believe there are lots of avenues for their financial capabilities work to 

reach a broader audience. 

On opportunities to improve. I appreciate the Bureau’s culture and genuine attempts to 

constantly seek ways to improve. From my perspective as an investor in consumer friendly, forprofit financial innovation, I’d encourage the Bureau to do more with Project Catalyst, on 

regulating initial coin offerings (ICOs), to dig into behavioral economics more, to further 

promote and protect immigrants, minorities and the elderly, and wield the power of soft 

persuasion more. 
corevc.com	|	1680	Vine	Street,	Suite	606	|	Los	Angeles,	CA	90028

Project Catalyst should do more to partner with Fintech companies and the Bureau has to lower 

the hurdles for supporting experimentation. It should give guidance earlier and more clearly 

during its rule-making process. It should prioritize finding ways to leverage technology leaders’ 

skills and scale to advance more consumer friendly financial services. 

Initial Coin Offerings have raised $1.3 billion in the first half of this year alone and will almost 

certainly result in massive losses to average, non-accredited retail investors. Where the CFPB 

can’t regulate it could create first principles for protecting consumers and work with appropriate 

regulators toward those ends. 

The field of behavioral economics can dramatically change the face of financial services, in 

consumers’ favor. The Bureau has done some work here, but is just scratching the surface, in my 

humble opinion. I’d love this become a rich exploration, akin to what you have done with 

alternative data. Companies like Blast, Digit, and Hugo are reimagining how people can align 

with their better selves. 

Especially considering the current political environment, I believe the Bureau could double its 

efforts to empower immigrants (e.g. Nova Credit and mPower), minorities, and the elderly (e.g. 

TrueLink and BluePrint Income). Fintech entrepreneurs are doing some extraordinary work 

here. 

Finally, I think the Bureau could expand and promote its efforts to persuade without 

enforcement. The letter you wrote to big credit card issuers that their customers would benefit 

from access to a free credit score, is a fantastic example. How about sending the same letter to 

the long tail of smaller banks? I’m sure the CAB could help identify a handful of high-impact 

letters you could write encouraging big wins for both consumer and industry. 

On the CAB itself. It’s fantastic that the board consists of such diverse participants, including a 

record five members of the Fintech community. I’ve been impressed by your personal 

commitment to leverage the board as a window into our industry, as well as the Bureau’s team’s 

professionalism and commitment to the mission. I’m grateful to outgoing CAB Chair, Maeve 

Brown, who brought tremendous patience, levity and decorum to her role.

Sincerely,

Arjan Schütte 
 

September 2017 

Honorable Richard Cordray 

Director, Consumer Financial Protection Bureau 

1700 G Street, NW 

Washington, D.C. 20552 

Dear Director Cordray: 

I am pleased to provide my reflections on my first year as a member of the Consumer Advisory 

Board (CAB) of the CFPB. I admire all of the good work by the CFPB, and it’s been a great 

honor and a great experience for me to serve on the CAB. 

I’ve learned so much from both the CFPB staff presentations and the insightful conversations 

that we’ve had on the CAB. The conversations are incredibly valuable because they come so 

many different perspectives. The back-and-forth engagement has been lively, while one of the 

most interesting aspects has been unexpectedly finding areas of agreement. I’ve very much 

appreciated how both the CFPB staff and the outgoing CAB Chair have consistently provided 

sufficient “space” for all CAB members to share their perspectives. 

I hope to have made meaningful contributions to the CAB, especially on the issues of credit 

reporting, overdraft practices, debt collection, and credit cards. The focus on using alternative 

data to help “credit invisibles” has been an interesting topic, and I am glad to be able to convey 

our concerns that such efforts be made in a way that does not actually end up hurting low-income 

and other vulnerable consumers. It was also exciting to see the presentation to the CAB of the 

Supervisory Highlights Report on how CFPB’s supervision has begun to improve systems for 

accuracy at the nationwide consumer reporting agencies, and to be able to give feedback on that 

topic later during that meeting. 

One of the best things about the CAB is getting to meet so many of the dedicated, smart, and 

hard-working staff members of the CFPB. Thank you for your own personal engagement with 

the CAB, for your leadership as Director, and for the opportunity to be part of the CAB. 

 Sincerely, 

 

 Chi Chi Wu 
CFPB Annual Report - 2017

I have been honored to serve as a member of CFPB’s Consumer Advisory Board (CAB) for the third 

year, fulfilling my term. I have found participation as a member of the CAB to be a fulfilling, 

demanding and deeply illuminating experience. I am pleased that I have been able to support the 

mission of CFPB and contribute to the financial health of Americans. I commend CAB members and 

CFPB staff for their commitment, discipline and expertise. They serve America with distinction.

My primary focus as a CAB member has been on mortgage finance matters. This past year, we 

focused on the evolution of Treasury’s Making Home Affordable (MHA) program or “Life after 

HAMP.” MHA established a national framework for loss mitigation consumer support which we 

were concerned about losing as MHA expired. Through the lead work of the Mortgage Markets team, 

CFPB has encouraged broad support for the continuation of borrower engagement and support 

systems. The CAB also experienced the evolution of mortgage servicing rules this year and the 

relationship of RESPA to the provision of housing counseling to prospective borrowers.

Access to affordable mortgage credit by lower income/credit challenged borrowers remained a 

major concern in 2017. Numerous factors have driven this phenomena but we considered whether 

QM rule-making may have had an impact and what measures may improve the availability of 

funding for low balance mortgage loans. 

Another concern were stories about the proliferation of land contracts in lending to lower income 

and minority residents. The CAB shared experiences and encouraged the Bureau to conduct 

research to determine the extent that this form of financing take place and to develop measures to 

restrict or restrain its utilization.

Gene A. Spencer

SVP, Stakeholder Engagement, Policy and Research
www.futurion.digital

August 30, 2017

Honorable Richard Cordray

Director, Consumer Financial Protection Bureau

1700 G Street, NW

Washington, DC 20552

Dear Director Cordray,

After the conclusion of them three-year term on the Consumer Advisory Board (CAB), I would 

like to take the opportunity to share my thoughts. I have been impressed with the commitment 

of the agency to look out for the health and well-being of consumers, while always considering 

what is viable for the financial services industry. As a researcher, I see abundant evidence that 

consumers are often overwhelmed by ever-increasing complexity of the financial services 

industry. 

I am particularly concerned about how political forces could upend the agency's commitment 

to consumer financial health, and appreciate agency members' demonstrated willingness to 

simply go about their job despite external politically-driven uncertainties. As a researcher, it is 

clear that many consumers and small businesses in particular are still reeling from the effects of 

the historic 2008 financial services meltdown, and appropriate continuity is vital to the health 

and stability of our economy. 

I appreciate how the agency has paid particular attention to financial technology ("fintech") 

trends. Our CAB meetings have been marked by numerous discussions about how emerging 

technologies are or could change the face of consumer financial well-being, with additional 

consideration of the impact on the industry overall. 

I would like to encourage the CFPB to consider technologically-advanced research methods that 

are also more representative of how consumers’ unique experience differs with various major 

financial providers. My interaction with the agency's researchers have found there is generally a 

preference toward historically-accepted research methods that may no longer reflect the 

overall US population–such as those that primarily rely on phone-based polling. I believe there 

would also be value in having the CFPB share selected findings from such data publicly, in ways 

that ground healthy public discovery or debate in empirical data. 

I am thankful for the privilege of serving on the CAB, and wish the agency much success in its 

endeavor to make financial services work for everyone.

Sincerely,

Jim Van Dyke,

Founder and CEO

Futurion
Joann Needleman

T 215-640-8536

F 215.640.8501

Email: jneedleman@clarkhill.com

Bio: www.clarkhill.com/people/joann-needleman

Clark Hill PLC

One Commerce Square

2005 Market Street

Suite 1000

Philadelphia, PA 19103-7041

T 215.640.8500

F 215.640.8501

clarkhill.com

Bi

205572407

Director Richard Cordray

Consumer Financial Protection Bureau

1275 First St. N.E.

Washington, D.C. 20002

RE: Consumer Financial Protection Bureau’s

Consumer Advisory Board

Final Assessment

Dear Director Cordray:

As an outgoing member of the Consumer Financial Protection Bureau’s (CFPB or Bureau )

Consumer Advisory Board (CAB), I have been asked to provide and share my thoughts on my

time served on the Board.

It was an honor and a privilege to be selected as a member of the CAB. I know that the CFPB

values and respects what the CAB provides and their selection process for CAB members

reflects this belief. As one of a few industry members and the first member from the debt

collection industry, I was encouraged that the Bureau wanted to learn from my experiences in the

hope that my perspective could provide assistance to the Bureau as it proceeds in the rule making

process for debt collection.

I felt that the private sessions with the CAB and Bureau Staff encouraged a healthy dialogue of

various opinions and perspectives. There were times that the CAB agreed with the CFPB on

certain issues and there were times that the CAB communicated a belief that more work was

needed. In those instances, the Bureau listened.

For me the most valuable aspect of being on the CAB was collaborating with the other CAB

members. In my career, I have only met a few consumer advocates in passing; maybe speaking

on a panel or two with some, but I never really had the opportunity to converse at length or get to

know one person in particular. The CAB bridged that gap. What I came to realize is that industry

representatives and consumer advocates have a lot more in common than we have differences.

While we may disagree on how to get from Point A to Point B, our belief in outcomes, especially

as it could benefit the consumer, are very much the same. I hope the Bureau will recognize this
Director Richard Cordray

Page 2

205572407

alignment and encourage more collaboration from both industry and advocates prior to

facilitating certain policies. While it is understandable that a federal agency with the name

“consumer” in its title will always put the consumer first, industry can be the solution and not

always the problem.

If there is one critique I would make, it would be that I did not feel we were a true “advisory”

board. Our roles as members were never completely defined. While we were given opportunities

to comment on specific Bureau activities, the overall philosophy of the Bureau and future

strategic discussions never occurred. Since a healthy majority of the members were fully

supportive of the Bureau’s mission, those of us who may have had disagreements about certain

Bureau’s activities found little opportunity to express those concerns. I believe the CAB could

have been of great assistance to the Bureau during periods of criticism, providing perspective

and navigation during those rough patches. As the Bureau moves into a period of uncertainty, I

hope it will seek advice and counsel from existing and future CAB members. Additionally, I

hope those CAB members will provide candid and frank recommendations.

I want to thank the Bureau staff for all their assistance. They always kept us well informed with

Bureau activities while at the same time having to be logistics experts.

I wish all the best to you and the CFPB.

Very Truly Yours,

CLARK HILL, PLC

Joann Needleman, Esq.

/JN
INTERFAITH CENTER ON CORPORATE RESPONSIBILITY 

Inspired by faith, committed to action. 

________________________________________________________________ 

________________________________________________________________

475 Riverside Drive, Suite 1842, New York, NY 10115-0050 Phone: 212-870-2295 Fax: 212-870-0023 

www.iccr.org 

September 14, 2017 

Honorable Richard Cordray 

Director, Consumer Financial Protection Bureau 

1700 G Street, NW 

Washington, D.C. 20552 

Dear Director Cordray: 

It has been a great privilege to serve on the Consumer Advisory Board these last two years. It has given me 

the opportunity to see up close the breadth and depth of the pressing issues that the CFPB is tackling in its 

rule-making, supervision, and enforcement, issues which deeply affect so many Americans. The thorough, 

thoughtful, and balanced way in which the Bureau approaches its mandate has really stood out for me. The 

in-depth conversations that we have had on the Consumer Advisory Board have been informed by detailed 

briefings and information from Bureau staff, and I have appreciated that staff and leadership at the Bureau 

are so responsive to suggestions and concerns raised by members of the CAB. 

I worked for many years prior to the 2008 financial crash fighting and exposing predatory lending, and 

providing legal representation to homeowners who were losing their homes to foreclosure due to rampant 

lending abuses. In these years, there was a huge void in regulatory oversight at the federal level, allowing 

these abuses to flourish un-checked, and leading to the financial crash. While there were seven federal 

agencies ostensibly regulating banks, there were no agencies that were focusing on the impact of financial 

practices on families, communities, and small businesses. 

Post Dodd-Frank, the CFPB has fulfilled this role ably, and with a high degree of commitment and integrity. 

For the first time, there is an agency in Washington that is truly focused on how financial practices affect all 

Americans. For the first time, and with enormous benefit to the public, there is careful and thorough 

oversight over a whole range of financial services industries and practices that had previously existed in an 

unregulated “wild west”, such as mortgage and student loan servicing, debt collection, payday lending, 

credit reporting, and auto lending. The CFPB’s systematic oversight over these industries has helped weed 

out widespread exploitative practices, and has leveled the playing field for banks and financial services 

companies that are conducting honest business that benefits the public. 

Participation in the CAB has shown me how seriously the CFPB takes its mandate across the board. For 

example, while the enforcement actions garner more attention, the Bureau tackles its financial education and 

research duties with the same level of thorough analysis and attention to detail. This work provides critical 

information and data to the public, which helps families and businesses make the right financial decisions 

on a wide range of issues. 
In the year ahead, the CFPB will be continuing the critical rule-making process on issues that affect a huge 

number of Americans, including small business data collection, debt collection, and small dollar lending. 

I’m honored to serve with my distinguished colleagues on the CAB, and look forward to giving feedback on 

the important work that the CFPB is doing. 

Sincerely, 

Josh Zinner 

Chief Executive Officer 

Interfaith Center on Corporate Responsibility 



September 14, 2017

Honorable Richard Cordray Director

Consumer Financial Protection Bureau 

1700 G Street, NW 

Washington, D.C. 20552 

Dear Director Cordray:

As I enter my final year on the CAB, I regret that my term will soon be ending.

The past year has been tumultuous with the change in the administration and a great deal of public 

debate about CFPB regulations at various stages in the regulatory pipeline, including arbitration, 

overdrafts, debt collection, and payday lending. Despite the challenges and distractions, the staff of 

the CFPB has continued its measured, thoughtful and informed process of evaluating whether and 

how to regulate consumer financial products. 

The staff is not afraid of complexity. In fact, whenever staff members present questions to the CAB, 

they highlight the nuances of proposed regulations, including their concerns about potential impacts

on the market and consumers. In turn, the discussions at the CAB invariably entail deep dives into 

the evidence in favor of and in opposition to regulations under consideration. Like the staff, the CAB 

members do not adopt strident positions. Rather, we collectively try to inform the CFPB’s efforts 

from our individual vantage points and without rigid mindsets.

The CFPB does more than educate, enforce and regulate. It is an agency that values learning. We 

have had many discussions about new technologies from blockchain to fintech. The conversations 

have not been with an eye to regulation or enforcement. Rather, the focus has been learning about 

these products, i.e. their models, risks, advantages to consumers, etc. Learning before acting should 

be foundational at all agencies.

From an enforcement and regulatory perspective, it is difficult to believe the CFPB could improve its 

processes or outcomes. My one concern is outreach. Not for lack of effort, the CFPB still is not well 

known to much of the public. I encourage the CFPB to double down on its efforts to educate people 

about its existence and how it serves consumers. Perhaps past and present CAB members—

particularly those who can reach out to people with a high need for help and less access to 
information—could help bring attention to the CFPB. Ideally, the CFPB could produce a single 

brochure and a quick slide show that outlines how the CFPB can help consumers.

I have worked with many federal and state agencies over the years. The CFPB continues to be the 

most efficient and effective agency I have ever encountered. It is a privilege to serve on the CAB.

Sincerely,

Kathleen C. Engel

Research Professor of Law
PennDesign

Department of City and Regional Planning

School of Design

University of Pennsylvania 

210 South 34th Street

127 Meyerson Hall

Philadelphia, PA 19104-6311

20 September 2017

Honorable Richard Cordray, Director

Consumer Financial Protection Bureau

1700 G Street, NW

Washington, DC 20552

Dear Director Cordray:

Thank you for providing the opportunity to reflect on my service on the Consumer 

Advisory Board over the past year. I was extremely honored to be nominated and 

then selected to serve on the board, and have had a truly valuable experience during 

my first year of service.

Throughout this past year I have been struck by the diversity of voices and 

experience around our table, as well as the seriousness with which the CFPB takes 

the CAB’s input. It has been a real privilege to engage with my fellow committee 

members and with your staff on the wide range of issues that fall under the 

consumer financial protection umbrella. I am impressed with the seriousness, 

expertise and professionalism of your staff, and the depth of research they conduct 

on complex problems.

Serving on the Consumer Lending Subcommittee has given me greater insight into 

issues concerning student debt, the use of alternative credit, and auto lending, to 

name just a few examples. As the credit markets have become more complex and 

creditworthiness has grown in importance, the work of the CFPB has become even 

more key. I particularly appreciate the seriousness with which you take the input of 

the CAB and the fact that you dedicate time to our meetings. 

I’ve found that my participation on the Consumer Advisory Board works in two 

ways. I bring my expertise and knowledge to our meetings and our work, and I also 
bring what I’ve learned through my participation back to my own research. My 

depth of knowledge and understanding of policy issues has grown as a result.

The CFPB plays a critical role in the consumer financial services landscape, and I am 

proud to have played even a small role in this important work.

Sincerely,

Lisa J. Servon

Professor and Chair



Honorable Richard Cordray 

Director

Consumer Financial Protection Bureau

1700 G Street

Washington, DC 20552

Dear Director Cordray:

My two years as a member of the Consumer Advisory Board has provided me the 

opportunity to engage in conversations on many critical issues involving financial 

products, services and practices, governing regulations, and their impact on the 

lives of consumers. In these discussions, I have been impressed with the 

commitment and professionalism of the CFPB staff as they carefully weigh issues, 

examine facts and create a respectful environment for dialogue. My own thinking on 

issues has also benefitted from the different perspectives offered by a diverse 

Advisory Board whose members share a common commitment to improve the 

financial well being of consumers. 

Over this period, CFPB staff engaged the Advisory Board in a series of discussions on 

policy and potential rule making addressing topics such as third party debt 

collection, small dollar lending, and arbitration in their pursuit of consumer 

protection remedies under mandates created out of Dodd-Frank legislation. In 

addition, topics with broad economic and social implications such as student loan 

debt, alternative financial data uses, and Fintech innovation formed a meaningful

part of the items put in front of the Advisory Board. I have been particularly 

gratified to see approaches to improve the impact and reach of financial education 

as a key part of the Bureau’s agenda.

Reflecting on the Bureau’s approach to certain issues, I do see opportunities to 

improve its impact by being more comprehensive and strategic in their 

assessments. For example, while clear about its desire to curb abusive payday 

lending practices, I think the Bureau is less clear about the consequences of 

potential rule making on credit availability or on overdraft fees. Also, while the 

Bureau’s concentration on curing student loan servicing defects will certainly 

provide relief to impacted consumers, a more upstream focus on underwriting and 

qualifying criteria would have greater impact on default rates and likely benefit 

more people. In both of these cases, the Bureau’s approach could benefit from 

framing the issue inside a set of clear outcomes that would better identify 

interdependencies, focus problem solving, and likely result in more sustainable rule 

making. 

As it looks to the future, I would encourage the Bureau to take more proactive steps 

to enhance the public’s awareness of its work in the areas of credit availability and 

financial education. While well known for its support of consumers by securing 

financial remediation through high profile enforcement actions and rule making, the 

Bureau is doing equally important, but less well defined work providing consumers 
with tools to improve their financial well being. Born out of Dodd-Frank legislation, 

the Bureau’s mission, identity, and core agenda has been driven by needs made 

apparent in the 2007 Financial Crisis, and has delivered an impressive record of 

results. I think our current economic environment, and a more complex, digital and 

data driven financial world argues for a broader, refreshed definition of “Consumer 

Protection” that the CFPB, prudential regulators, legislators, and financial service 

providers align around and collaborate to make consumers lives better.

Respectfully,

Neil F. Hall
CALIFORNIA REINVESTMENT COALITION

474 Valencia Street, Suite 230 San Francisco, CA 94103 tel 415.864.3980 fax 415.864.3981 www.calreinvest.org

Board of Directors

PAUL AINGER

Chair

Rural Community 

Assistance Corporation

STEPHANIE CARROLL

Vice Chair,

Public Counsel Law Center

ROBERTO BARRAGAN

Secretary

LUIS GRANADOS

Treasurer

Mission Economic

Development Agency

CHANCELA AL-MANSOUR

Housing Rights Center

MICHAEL BANNER

Los Angeles Local Development 

Corporation

GWENDY DONAKER BROWN

Opportunity Fund

MAEVE ELISE BROWN

Housing and Economic Rights 

Advocates

GLORIA BRUCE

East Bay Housing Organizations

ISELA GRACIAN

East LA Community Corporation

SHARON KINLAW

Fair Housing Council of the 

San Fernando Valley

APPASWAMY “VINO” PAJANOR

Housing Opportunities Collaborative 

WILLIAM PAVÃO

JOSEPH RIDOUT

Consumer Action

NAMOCH SOKHOM

Pacific Asian Consortium 

in Employment

STEPHON TAYLOR

California Resources and Training

ROBERT VILLARREAL

CDC Small Business Finance

CLARENCE WILLIAMS

California Capital

PAULINA GONZALEZ

Executive Director

Director Cordray

Consumer Financial Protection Bureau

1600 G Street NW

Washington DC 20552

Dear Director Cordray,

It has been an honor to serve on the Consumer Advisory Board during the past 

year and to see how the Bureau approaches its mandate to ensure that banks and 

other financial companies treat consumers fairly. As you know, California was 

the epicenter for the mortgage meltdown that resulted in millions of foreclosed 

homes, millions of lost jobs, and a deepening of the wealth gap in this country 

that will take decades to overcome. The passage of Dodd-Frank and the creation 

of the CFPB was a watershed moment in terms of preventing another harmful 

collapse whose impact was felt most deeply on Main Street. From my vantage 

point on the CAB, I have seen that CFPB staff take this responsibility seriously, 

and have created a new threshold for how regulators should protect consumers by 

putting a stop to harmful practices; increasing transparency about consumer 

complaints; and creating accountability for illegal behavior.

Small businesses are the economic engines of our economy, and yet we know 

from the Bureau’s recent white paper as well as a survey we recently conducted 

of our own members that access to safe and transparently priced financing 

remains a large obstacle for far too many small business owners, especially 

women entrepreneurs and entrepreneurs of color. It was gratifying to have the 

opportunity to present on this topic as part of our CAB meeting in June this year, 

and we are also excited to see the CFPB move forward on the 1071 rule to 

increase transparency.

The CFPB’s education, outreach, and enforcement work related to reverse 

mortgages continues to be an important asset and housing protection issue, 

especially as our senior population increases by 10,000 people every single day. 

Another area we have watched closely is the Bureau’s work to implement a rule 

on payday, car title, and other high-cost installment loans. These loans have been 

particularly harmful for low-income consumers in California because of our state 

legislature’s inability to prioritize protecting consumers over profits. 

Disappointingly, recently released state data indicate that seniors were the largest 

age group of borrowers in California last year.

I am deeply appreciative of the opportunity to serve with a diverse group of 

experts and to play a role in bringing the consumer and community voice to the 

CFPB as it moves forward on its important work.

Sincerely, 

Paulina Gonzalez 


Telesca Center for Justice

One West Main Street, Suite 200  Rochester, NY 14614

Phone 585.454.4060  Fax 585.454.2518

www.empirejustice.org

Albany  Rochester  White Plains  Long Island

September 13, 2017

Honorable Richard Cordray, Director

Consumer Financial Protection Bureau

1700 G Street, NW

Washington, D.C. 20552

Dear Director Cordray,

I am writing to express my deep appreciation to you for the opportunity to serve for the last year 

as a member of the CFPB’s Consumer Advisory Board (CAB). I have been working on access to 

credit issues for decades and the CAB has enabled me to deepen my knowledge of the credit 

products that consumers use. The reading materials, as well as the extensive in-depth 

conversations with staff and the other CAB members, are exceptionally productive. As a 

consumer advocate I value the honest discussions with CAB members who represent the lending 

industry and I have gained valuable insight from their perspectives. These conversations play an 

important role in crafting my thinking about existing and future regulations and therefore allow 

me to be a better advocate for the consumers I serve. 

I consistently find that all of the CAB members have a wealth of knowledge and expertise to 

share. The CFPB staff, who are assigned to specific issues areas, have extensive backgrounds in 

their areas of law and raise pertinent questions for CAB discussions. CFPB research papers and 

presentations play an important role in my work both on the CAB and in my professional 

capacity. The recent reports on borrowers who enter the credit economy and small business 

loans are just two recent examples. The CFPB research, based on detailed data sets, will prove 

to be critical to our work on policy solutions at the local and state level in New York State.

Unfortunately, many New Yorkers have very limited access to safe small dollar loans. Local 

advocates tell us that people of color in Rochester are systemically paying more for used car

loans. Used car loans are critical for workers who live in upstate NY to purchase cars which will 

provide the necessary transportation to better jobs. These higher paying jobs are typically not in 

close proximity to public transit or affordable housing, and have irregular hours making public 

transit even less useful. Those workers, who frequently maintain 2-3 jobs, still do not earn

enough to pay rent, put food on the table and meet the basic necessities of life. It is a travesty that 

those same New Yorkers are faced with borrowing on unfair and even abusive terms. It is 

imperative that consumers in our credit economy have access to fair, safe and affordable credit. I 

am committed to working with you and the CFPB to change that.
2

I thank you and your staff for this unique opportunity to serve my fellow New Yorkers. I am 

grateful for the enforcement actions and consumer protections enacted by the CFPB and I look 

forward to continuing this valuable work with you. 

Yours truly,

Ruhi Maker, Esq.
September 20, 2017 

The Honorable Richard Cordray 

Director 

Consumer Financial Protection Bureau 

1275 First Street, N.E. 

Washington, D.C. 20020 

Dear Director Cordray, 

It has been a great honor to serve on the CFPB’s Consumer Advisory Board (CAB) over the past 

two years and to have the opportunity to work more closely with the talented and committed staff 

of the CFPB. In a short period of time, the CFPB has move forward with an enormous amount of 

critical enforcement actions, regulatory policies, research, and materials developed directly for 

consumers that will have a lasting impact on the lives of so many Americans. 

The CFPB’s data and fact-driven approach is one of its greatest strengths. It has strived to obtain 

consistent input and insight from those most impacted by policies and markets that are overseen by 

the CFPB. It is also improving our ability to document and identify needs and opportunities for 

consumers. For example, having a final rule on the Home Mortgage Disclosure Act that includes 

additional reporting requirements on race and ethnicity of consumers will greatly improve industries’ 

ability to identify gaps in credit access as well as for consumer advocates to identify potential areas 

of concern where equitable access to credit is not available to all creditworthy consumers. The 

research and thought in developing a system to collect data on small business lending will also have 

a profound impact in the field. We hope the CFPB will move this work forward as expediently as 

possible and ensure there is disaggregated data by race and ethnicity as well. This initiative will 

serve to support entrepreneurs across the country that keeps the U.S. economy and local 

neighborhoods thriving. 

Other bodies of work, including the rules to improve the Real Estate Settlement Procedures Act and 

the Truth in Lending Act, the arbitration rule, and others, will ensure that consumers are more 

informed about the commitments they are making, and to enable them to enforce their own rights 

as consumers. We applaud the CFPB for moving these policies forward with the best interest of 

consumers as the primary focus. 

The incredible amount of user-friendly tools and guides available at the Bureau, along with tools for 

consumers and practitioners, serve not only to inform consumers but also helps build the capacity of 

local organizations that are working directly with the most at-risk consumers. Tools such as those 

developed for students, seniors, and their caregivers show that the CFPB is responding to what it is 
hearing in the field. We -commend the thoughtful approach to the development of these tools and 

the simple format that is utilized for consumers to better access. 

Lastly, I appreciate the chance to share the experiences of those Americans with Limited English 

Proficiency (LEP) as well those that are culturally isolated, with members of the CAB and the CFPB. 

Over the past few years, we have made progress in reaching these communities, but there is much 

more work to do. I look forward to continuing this work in years ahead to increase access to 

resources, the complaint line, and other engagement opportunities offered by the CFPB. 

As the CFPB continues to move forward with its critical mission, I thank you for the opportunity to 

share my perspective and to lend a voice on behalf of the Asian American and Pacific Islander 

community. 

Sincerely, 

Seema Agnani 

Executive Director