The central mission of the Consumer Financial Protection Bureau (CFPB) is to make markets for consumer financial products and services work for Americans—whether they are applying for a mortgage, choosing among credit cards, or using any number of other consumer financial products.
The CFPB will be supervising financial institutions to help ensure that consumer financial products, services, and practices conform to federal consumer financial protection legal requirements and aren’t unfair, deceptive, or abusive. At times disputes will emerge as these financial institutions will wish to appeal the findings of the supervision process, particularly when those findings call for corrective actions and potential public enforcement proceedings. The CFPB is staffed with employees who have transferred from a number of different agencies with different appeals processes; implementing a specific process will require a persuasive proposal backed by extensive research. HNMCP will research various appeals models and survey stakeholders on current practices with the aim of designing a dispute resolution appeals process to be implemented by the CFPB
- Researching the various appeals models employed by federal and state regulators
- Developing a list of the pros and cons of allowing appeals of supervisory findings and conducting stakeholder interviews to gather opinions on the current practices of agencies
- Designing potential appeals models consistent with the CFPB’s values, mission and vision and surveying opinions regarding proposed appeals models
Report and presentation detailing the findings of the students’ research, possible options for the CFPB’s appeal process, and a recommendation or proposal for a specific model, including best practices of regulatory appeals processes and a summary of stakeholder views of various models currently employed by other agencies