In a new Report to Congress, the Government Accountability Office ("GAO") urged the Consumer Financial Protection Bureau ("CFPB") to implement a systematic process that would efficiently prioritize and address significant consumer risks.

In its review, the GAO assessed how the CFPB identifies, monitors and reports consumer risks. According to the GAO, although the CFPB established a process for determining policy priorities based on market data and other information in 2015, the agency has not yet decided whether it will continue to use this process to set priorities. As a result, the GAO found that the "CFPB currently lacks a systematic, bureau-wide process for prioritizing financial risks to consumers and [for] considering how it will use its tools—such as rulemaking, supervision, and consumer education—to address them."

The GAO urged the CFPB to establish such a systematic process in accordance with the Dodd-Frank Act requirement that the CFPB monitor consumer risks when undertaking the development of rulemakings and federal internal control standards. The GAO emphasized that CFPB management should (i) "use quality information to achieve agency objectives" and (ii) "identify, analyze, and respond to risks related to achieving the defined objectives." Further, the GAO stated that such a process would ensure that the CFPB is (i) focusing on the "most significant financial risks to consumers" and (ii) "meet[ing] its statutory consumer protection objectives."

While the CFPB agreed that having such a systematic process is important, it did not agree or disagree with the GAO's specific recommendations.

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