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CFPB watchdog outlines areas of improvement for the regulator

Specifically looks at examination workpaper documentation practices

As the Consumer Financial Protection Bureau continues to develop, a report from the Office of Inspector General for the Consumer Financial Protection Bureau found some areas the bureau could work on.

The CFPB is still early in its existence, only coming into fruition in 2011 after the financial crisis.

Even though none of the results are game-changing findings against the CFPB, they do outline areas the bureau could work on, and the OIG will follow up to ensure that the recommendations are fully addressed.

As outlined in a blog post from Ballard Spahr, according to a recent report from the OIG, it reviewed workpaper documentation in each of the CFPB’s four regions for compliance with the CFPB Supervision and Examination Manual and other policies that govern examination work.

The bureau’s Division of Supervision, Enforcement, and Fair Lending (SEFL) conducts the agency’s supervision activities, and this new report identifies opportunities for the division to improve its workpaper documentation practices.

According to the report, the division’s approach was to grant examination employees within each region open access to all examination workpaper documentation and supporting materials in the initial system of record and on the current shared drive for examinations conducted in that region.

However, the open-access-within-each-region approach resulted in certain division employees to have access to materials with confidential supervisory information and personally identifiable information when they did not appear to have a business need to know that information, the report explained. 

Additionally, the OIG found that file size limitations in the initial system of record led examiners to store workpapers in multiple locations. We also found opportunities to reinforce the need to store workpapers in the appropriate location and to document supervisory reviews and sampling methods.

As a result, the OIG recommends that the SEFL develop workpaper training and an ongoing quality review process.

In response to the OIG’s draft report, the CFPB stated, “The bureau appreciates the OIG’s review and agrees with the recommendations for improving practices relates to examination workpapers.”

“As noted in the report, the bureau made significant improvements to its policies, procedures, and capabilities around workpaper management since the beginning of the review period and continues to do so,” it stated. “Accordingly some of the recommendations have already been implemented, and the bureau is committed to taking steps toward implementing the remainder.”

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