CFPB Releases Five-Year Strategic Plan

The plan adheres to the bureau’s statutory responsibilities, including addressing ‘burdensome regulations,’ as it lays out a more balanced and restrained vision for the CFPB.

2/13/2018 1:00 PM

CFPB Releases Five-Year Strategic Plan

The Consumer Financial Protection Bureau released its five-year Strategic Plan Feb. 12 to establish its mission, strategic goals and objectives based on its authorities under the Dodd-Frank Act. The updated Strategic Plan, which is a revision of the draft released in October 2017 under former CFPB Director Richard Cordray, reflects the philosophy of statutory-based leadership espoused by Acting Director Mick Mulvaney. 

“If there is one way to summarize the strategic changes occurring at the Bureau, it is this: we have committed to fulfill the Bureau’s statutory responsibilities, but go no further,” Mulvaney said in a news release. “By hewing to the statute, this Strategic Plan provides the Bureau a ready roadmap, a touchstone with a fixed meaning that should serve as a bulwark against the misuse of our unparalleled powers.”

Under the new plan, the CFPB lays out the following revamped mission and vision:

Mission: “To regulate the offering and provision of consumer financial products or services under the Federal consumer financial laws and to educate and empower consumers to make better informed financial decisions.

Vision:  “Free, innovative, competitive, and transparent consumer finance markets where the rights of all parties are protected by the rule of law and where consumers are free to choose the products and services that best fit their individual needs.”

The CFPB also lists four tenets for how it will approach its work in the next five years, underscoring the vast difference between the current CFPB and that under former Director Richard Cordray.  Specifically, the plan states the CFPB will achieve its mission and vision through:

  • Seeking the counsel of others and making decisions after carefully considering the evidence.
  • Equally protecting the legal rights of all.
  • Confidently doing what is right.
  • Acting with humility and moderation.

In terms of the CFPB’s rulemaking authority, the plan lists several strategies, many of which are relevant to the debt collection industry including:

  • Conducting empirical assessments to evaluate the effectiveness of significant Bureau rules in achieving the purposes and objectives of the Dodd-Frank Act and the CFPB’s specific goals.
  • Periodically reviewing individual regulations to identify opportunities for clarification, modernization and streamlining.
  • Engaging in rulemaking where appropriate to address unwarranted regulatory burdens.
  • Carefully evaluating the potential benefits and costs of contemplated regulations.
  • Promoting practices that benefit consumers, responsible providers, and the economy as a whole.

In addition, the Strategic Plan highlights the importance of the CFPB keeping pace with changing technology, an issue hugely important to debt collectors who struggle to apply the four decades-old Fair Debt Collection Practices Act to modern communications technology. 

“In recent years, evolving technologies have driven rapid change in the consumer financial marketplace,” states the plan. “The swift pace of change can provide benefits, opportunities and risks to both consumers and institutions. The Bureau must keep pace with the evolution of technology in consumer financial products and services in order to accomplish its strategic goals and objectives.”

The updated Strategic Plan demonstrates how impactful new CFPB leadership can be to the mission of the bureau going forward.  By espousing appropriate restraint and a balanced outlook on its role, this plan positions the CFPB to be able to ensure a well-run, effective consumer financial marketplace that benefits consumers without harming legitimate businesses.  Developing well-reasoned, workable debt collection rules to provide clarity to an outdated statute falls squarely within the CFPB’s Strategic Plan and ACA looks forward to working with the bureau to help achieve this important goal.

The complete Strategic Plan is available on the CFPB’s website.

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