We would be hard pressed to ensure that markets for consumer financial products and services are fair, transparent and competitive without the trust of citizens and financial institutions in our work. To build and protect that trust, we are working to establish a strong ethics and compliance program.
As part of this effort we have determined that the existing government ethics laws and regulations, while robust, do not sufficiently address the ethics issues posed by the mission and responsibilities of the Bureau. To address these issues, we published our own ethics regulations that cover all Bureau employees. These CFPB-specific regulations establish:
- Restrictions on outside employment and business activities ;
- Prohibitions on the ownership of certain financial interests;
- Restrictions on seeking, obtaining or renegotiating credit and indebtedness;
- Prohibitions on recommendations concerning debt and equity interests;
- Disqualification from participating in certain Bureau matters based on credit or indebtedness;
- Prohibitions on purchasing certain assets; and
- Restrictions on participating in particular matters involving outside entities.
We carefully studied the ethics regulations of other financial regulatory agencies, such as the Federal Deposit Insurance Corporation , the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency when crafting our own rules. In many cases the Bureau’s rules are very similar to the rules imposed by other financial regulatory agencies. For example, the Bureau will require that all employees seek prior approval before engaging in outside employment.
In other cases, however, the new rules are modified to reflect the scope of the Bureau’s supervisory authority over both banks and nonbanks that provide a wide range of consumer finance products. For instance, the Bureau decided to create a list of specific financial holdings that employees may not own rather than a general prohibition on a class of financial holdings. This list is tailored to include only businesses that are subject to examination by the Bureau.
By taking these affirmative steps to ensure the Bureau’s work is not affected by actual or apparent conflict of interest concerns, we seek to build and maintain the trust of consumers and the financial institutions we oversee.
We welcome your comments. You may submit comments via email, mail, or hand delivery.
Consumer Financial Protection Bureau
Attention: Ethics Office
1700 G Street, NW
Washington, DC 20552