Earlier this week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its five-year Strategic Plan that establishes its mission, strategic goals, and strategic objectives. This Strategic Plan presents an opportunity to explain to the public how the Bureau intends to fulfill its statutory duties consistent with the strategic vision of its new leadership.
The CFPB is required to prepare and publish a five-year Strategic Plan in accordance with the Government Performance and Results Act (GPRA) and GPRA Modernization Act. The prior Strategic Plan was published in April 2013. This new plan is a revision of the draft released in October 2017.
CFPB Acting Director Mick Mulvaney states that in reviewing the draft Strategic Plan released by the Bureau in October 2017, “it became clear to [him] that the Bureau needed a more coherent strategic direction.” The plan draws directly from the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and refocuses the Bureau’s mission on regulating consumer financial products or services under existing federal consumer financial laws, enforcing those laws judiciously, and educating and empowering consumers to make better informed financial decisions.
Among changes from the prior Strategic Plan, the CFPB states that it will now focus on “equally protecting the legal rights of all, including those regulated by the Bureau, and will engage in rulemaking where appropriate to address unwarranted regulatory burdens and to implement federal consumer financial law and will operate more efficiently, effectively, and transparently.”
According to the Strategic Plan, the CFPB will achieve its mission and vision through: (i) seeking the counsel of others and making decisions after carefully considering the evidence; (ii) equally protecting the legal rights of all; (iii) confidently doing what is right; and (iv) acting with humility and moderation.
“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,” said Mulvaney. “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.”
We note that this revised Strategic Plan does not provide any information about existing or potential future regulations or enforcement or supervisory initiatives.