CFPB Releases 2018-22 Strategic Plan

CFPB Consumer Financial Protection Bureau Mick Mulvaney

The Strategic Plan establishes the CFPB's mission, strategic goals and strategic objectives for the next five years, and includes multiple revisions from a draft version released in October 2017.

Trump appointed one of the agency's most vocal critics, White House budget chief Mick Mulvaney, to be the bureau's acting director in late November.

In keeping with the Acting Director's philosophy, the Strategic Plan draws directly from the Dodd-Frank Act for its formulation of the Bureau's mission: "t$3 o 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".

"To prevent actions that unduly burden the financial industry and limit consumer choice, the proposal restricts CFPB's broad enforcement authority over Federal consumer law". "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".

Mulvaney defined the CFPB as "perhaps the most unaccountable bureau or agency there is", a reference to its status of not having to be held accountable to Congress. The plan would also diminish the CFPB's enforcement capabilities and cap the agency's budget at its 2015 level of $485 million, down from a projected $630 million in 2018.

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Goal 3: Foster operational excellence through efficient and effective processes, governance, and security of resources and information.

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However, the new strategic plan does change how the bureau approaches enforcement that follows those examinations.

"We have committed to fulfill the bureau's statutory responsibilities, but go no further", Mulvaney wrote in the preface to the report.

Along with NAFCU, the letter was also signed by the American Financial Servicers Association, Consumer Mortgage Coalition, Credit Union National Administration, HOPE NOW Alliance, Independent Community Bankers of America, and Real Estate Settlement Providers Council. Mulvaney has already taken several steps to shake up the agency, such as ending lawsuits and pausing investigations.

If the CFPB declines to repeal its amended rule, the letter asks that the bureau to revisit specific portions of the rule, including "the past-payment breakdown, servicer transfers, and pre-confirmation cases, among others".

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