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Thursday, October 2, 2014

CFPB Complies with Dodd-Frank Section 1100G, But Could Enhance Process

The Office of Inspector General (OIG) found that the CFPB complied with the provisions of Section 1100G of the Dodd-Frank Act as well as the two interim policies and procedures issued by the CFPB’s Division of Research, Markets, and Regulations (RMR). Section 1100G amended some provisions of the Regulatory Flexibility Act, requiring the CFPB to assess the impact of any proposed rule on the cost of credit for small business entities through regulatory flexibility analyses and to convene panels to seek direct input from small business entities prior to issuing certain rules.

However, the OIG found that RMR’s policies and procedures have not been updated during the two years they have been in use, and that the interim policies and procedures afforded teams significant discretion in their 1100G rulemaking approach to regulatory analysis, which contributed to a variance in documentation and inconsistent knowledge transfer practices.

The OIG recommends that the CFPB finalize RMR’s interim policies and procedures, establish a standard approach to manage electronic documents that facilitates retrieval of 1100G rulemaking supporting documentation and ensure that the standard approach complies with CFPB and other applicable provisions.

The CFPB has concurred with these recommendations and has outlined actions that have been or will be taken to address our recommendations.

Read the report.

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