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Know Before You Owe: Just one example of our approach to policy-making


As the mortgage disclosure team said last week, we based Know Before You Owe on the idea that disclosure information is clearer when the people who will have to use those disclosures participate in designing them. We got feedback from many sources in many ways:

  • In-person testing of the forms in cities across the country from consumers and from people in the mortgage industry, both before proposing the new disclosures and after;
  • Online publication of various iterations of prototypes of the forms as we tested them and getting more than 27,000 clicks and comments to tell us what worked (and what didn’t);
  • Quantitative validation study with about 850 consumers of how well consumers understand the new disclosures compared to the ones currently in use (we’ll talk more about the results of that study in the days to come); and
  • Ongoing dialogue with industry groups, financial institutions, consumer advocates, policymakers from across government, and designers throughout the design process.

This testing and iteration process occurred alongside legally required feedback such as a Small Business Review Panel before we issued the proposed rule, and the public comment period for the proposed rule.

We started this prototyping and research even before the Bureau began regulating consumer financial products and services. In the process, we established a pattern of public inclusion in what we create. We have since taken on additional projects that rely on this pattern to succeed. In each case, we believe it has made us better at our work and will continue to do so.

Consumer tools

In April 2012, we introduced a beta version of a tool to help students compare the costs of college. Based on the feedback we got, we made improvements and re-released it along with a number of other tools to help students understand paying for college.

Now we’re working on similar tools to help people interested in owning a home. In each case, we continue to take feedback. We don’t believe that products to help consumers understand their options are ever complete. When we make new consumer tools, we commit to analyzing how people use them. The tools should change as we understand more about what’s useful or necessary, and what’s not.

Making information more accessible

We maintain a regularly updated public database of consumer complaints we receive. We also maintain an API that lets people build on top of that data.

A few months ago, we created a new platform to publish home mortgage data. Not every good idea for using consumer financial market data is ours; these platforms give the public access to data about their own experiences.

Last month, we launched a prototype tool to make regulations easier to read, understand, and use. After a series of user interviews and a number of prototype usability tests, we’ve piloted eRegulations with one regulation. Before making any decisions on what to do with it next, we’re asking people who need to understand changes to Regulation E to use it and let us know how it works for them.

Prototyping better disclosures

The prototyping efforts of Know Before You Owe laid the groundwork for another initiative. Federal consumer finance regulations should protect consumers, not hinder innovations that help them. Through Project Catalyst, we work with innovators to do just that. Someone who spots a way to make regulations more innovation-friendly can work with us to design experiments. Someone who thinks there’s a way to make disclosures clearer can work with us to start a trial that tests how well their idea works.

Open source software

Source code written by our staff is public domain by default. Anyone can use and build on it as long as it meets a few standards. And we are committed to publishing it in an online source code community. CFPB Open Tech gives the public easy access to free, open source software they can use as the basis for their own new tools and approaches. In turn, we get to review ideas from other developers and decide whether to use them to make our software better.


In short, we value building things with public participation. It comes back to the same basic point: if you know people are going to have to use something, you should work with them to figure out what makes it useful. It’s an idea we have espoused since the start of Know Before You Owe, one we’re going to continue to build on.

Save the date, Mountain View, CA!


We invite you to participate in the CFPB’s Project Catalyst launch.

The program will take place on Wednesday, Nov. 14, 2012, at 10 a.m. PST at the Computer History Museum, 1401 N. Shoreline Boulevard, Mountain View, CA.

We’ll have remarks from CFPB Director Richard Cordray and Deputy Director Raj Date, as well as presentations by thought-leaders.

This event is open to the public and requires an RSVP.

Email with:

  • Your full name
  • Your organizational affiliation (if any)

See you there!

What do you think about our draft strategic plan for the next five years?


We have an expansive, vital mission: to make markets for consumer financial products and services work for Americans. But, how do we do that with limited resources?

We’ll accomplish our mission by setting goals, establishing strategies, and measuring performance. Our strategic plan outlines this information and describes how we will focus our resources on the areas where we can have the biggest impact.

Check out our draft
Today it’s just a draft – take a look at our strategic plan for 2013 – 2018.

What do you think?
We want your thoughts and ideas on how to improve our plan. Weigh in by emailing your comments on the plan to by October 25, 2012.

Save the date, St. Louis, MO!


Join us for the inaugural meeting of our new Consumer Advisory Board in St. Louis, Missouri.

The meeting will take place on Thursday, September 27, 2012, at 12:15 p.m. at Randall Gallery, 999 North 13th Street, St. Louis, MO.

We’ll have remarks from Richard Cordray, CFPB Director as well as the Chair and Vice Chair of the Consumer Advisory Board, board members, and members of the public.

This event is open to the public but you must RSVP. Feel free to forward this invitation.

Email with:

– Your full name
– Your organizational affiliation (if any)

See you there!

CFPB’s rulemaking agenda


Today, we are posting a semi-annual update of the CFPB’s rulemaking agenda. The Office of Management and Budget (OMB) has not published the full federal Unified Agenda yet, but this is the version we submitted to OMB.

Federal agencies typically release regulatory agendas twice a year. Each spring and fall, OMB works with the agencies to compile a list that outlines the rulemaking activities of all federal agencies for the coming 12-month cycle. It also includes recently-completed rulemakings. Cumulatively, the list is called the Unified Agenda of Federal Regulatory and Deregulatory Actions.

As an independent agency, we voluntarily participate in the Unified Agenda process. When OMB finalizes the spring 2012 Unified Agenda for the federal government as a whole, it will be published at To give the public additional time to consider our work prior to that, today we’re posting our final submission.

The CFPB’s agenda primarily includes rulemakings mandated by the Dodd-Frank Act. For example, we are working on several mortgage-related rules and rules to implement our supervisory program for certain non-bank entities. This includes two proposed rulemakings that we published for comment on Monday, July 9, relating to the Bureau’s Know Before You Owe mortgage disclosure integration project and setting forth new protections for high-cost mortgages. This also includes an initial rule to define nonbank “larger participants” that are subject to examination. The Bureau is publishing today a final rule regarding the Bureau’s supervision of larger participants in the credit reporting marketplace. We are also seeking your input on an Advance Notice of Proposed Rulemaking about the consumer general purpose reloadable prepaid card market.

Beyond specific rulemaking activity, we continue to work on a variety of initiatives that address issues in consumer financial markets. For example, last month we joined several other financial regulators in a memorandum of understanding to clarify the coordination of our supervision efforts. And Director Cordray recently met with Secretary of Education Arne Duncan and ten college presidents to finalize a commitment by those college and university systems to present clear financial aid offer information to all incoming students. They’re modeling this effort on the Financial Aid Shopping Sheet that the Department of Education and the CFPB developed last fall.

Stay tuned in this space for further semi-annual updates to the Bureau’s rulemaking calendar as we look ahead to 2013.

Making consumer complaints available to the public


Today marks a major step forward in our work to protect consumers. In a first by a federal financial regulator, the Consumer Financial Protection Bureau (CFPB) will share with the public individual-level consumer complaint data received by the CFPB.

Check out the Bureau’s policy statement for more details.

What does this mean for consumers?

No longer will consumer complaints only be known to the individual complainant, bank, regulator, and those in the public willing to pursue this information through the Freedom of Information Act. Instead this data-rich window into consumer financial issues will be widely available to everyone: developers, policymakers, journalists, academics, industry, and you. Our goal is to improve the transparency and efficiency of the credit card market to further empower American consumers.

And just to be clear, no personally-identifiable information, such as a consumer’s name, credit card number, or mailing address will be made available via the Consumer Complaint Database.

The Bureau’s Consumer Response function receives consumer complaints on a wide variety of products including credit cards, mortgages, student and other consumer loans, and other bank products (such as checking and savings accounts). And while the Consumer Complaint Database initially will contain only credit card complaints, the Bureau is proposing to extend the Database to all other consumer financial products and services covered by the CFPB.

What happens when a consumer files a complaint?

When a consumer files a complaint, Consumer Response intake specialists review each one for completeness, jurisdiction, and non-duplication. Complaints that meet these criteria are then forwarded to the appropriate company (bank or nonbank) for review and resolution. Companies are given 15 days to provide a substantive response to each consumer complaint, and are expected to resolve and close all but the most complicated complaints within 60 days.

Consumer Response prioritizes for investigation certain complaints based on a handful of risk-based criteria including the failure of a company to respond in a timely manner and those in which the consumer disputes the company-provided resolution. When potential legal violations are detected, Consumer Response works closely with other parts of the Bureau including the offices of Supervision, Enforcement, and Fair Lending to ensure potential violations are dealt with appropriately.

Throughout this process, consumers have the ability to log into the CFPB’s website to check the status of their complaint (and, when appropriate, dispute the resolution provided by the financial institution).

Why beta?

Today, we’re releasing the beta version of the Consumer Complaint Database. Why beta? While the complaint information in the database is actual data, the functionality, data fields, and “look and feel” of the database are all in the beta stage of development. In other words, this version of the Consumer Complaint Database is only the beginning. In addition to potentially enlarging the Database to include all other consumer financial products and services covered by the Bureau, we are looking into potentially expanding it in a number of other ways. These include the possible addition of narrative fields (to the extent we can do so while protecting personally-identifiable information), more sub-product and sub-issue data fields, regular and normalized data visualizations, and expanded data tools.

Lastly, you will note that initially the Database only contains complaints received by the CFPB on and after June 1st. Additional retroactive data will be added when we remove the “beta” tag later this summer.

What do you think?

We encourage you to tell us what you think about the Consumer Complaint Database by telling your story. All comments and suggestions are welcome.

Scott Pluta is the Chief of Staff and Acting Assistant Director for Consumer Response at the Consumer Financial Protection Bureau.