CFPB Releases Strategic Plan FY 2018 – 2022 amid Proposed Budget Cuts

Weiner Brodsky Kider PC

Weiner Brodsky Kider PC

The CFPB recently released its five-year Strategic Plan that outlines its mission, strategic goals, and objectives for fiscal years 2018 – 2022.  At the outset, in his Message from the Acting Director, Mick Mulvaney writes, “[I]f there is one way to summarize the strategic changes occurring at the [CFPB], it is this: we have committed to fulfill the [CFPB]’s statutory responsibilities, but go no further.”

Mulvaney also reiterates that the CFPB will no longer “push the envelope” but instead will follow the statutory mandate of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  Thus, according to Mulvaney, the Strategic Plan’s mission statement is drawn directly from the Dodd-Frank Act: to regulate consumer financial products or services under existing federal consumer financial laws, and to educate and empower consumers to make better informed financial decisions.  Further, Mulvaney states that the Strategic Plan provides the CFPB a ready roadmap that should “serve as a bulwark against the misuse of [the CFPB]’s unparalleled powers.”

To fulfill the CFPB’s mission statement, the Strategic Plan lists three long-term strategic goals:

  1. Ensure that all consumers have access to markets for consumer financial products and services.
    • This includes regularly identifying and addressing outdated, unnecessary, or unduly burdensome regulations to reduce unwarranted regulatory burdens.
  2. Implement and enforce the law consistently to ensure that markets for consumer financial products and services are fair, transparent, and competitive.
    • This includes enforcing federal consumer financial law consistently in order to promote fair competition.
  3. Foster operational excellence through efficient and effective processes, governance, and security of resources and information.
    • This includes managing risk and promoting accountability within the CFPB.

Around the same time that the CFPB released its Strategic Plan, the Office of Management and Budget, also led by current director Mulvaney, released the President’s Budget for fiscal year 2019 which proposes to reduce the CFPB’s budget by $147 million for fiscal 2019, capping funding to $485 million for 2019.  In addition, the budget proposes to subject the CFPB to the congressional appropriations process to receive funding under Congress starting in 2020, instead of independently receiving funding through the Federal Reserve system.  The stated purpose of the proposed reform is to impose financial discipline and reduce wasteful spending.  The President’s Budget is proposed and not yet final.

The CFPB’s Strategic Plan FY 2018 – 2022 is available here, and the President’s Proposed Budget FY 2019 is available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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