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The CFPB Can Strengthen Guidance on Cost-Increase Modifications

Contracts with large cost increases or scope changes can pose financial and legal risks to federal agencies. We reviewed 29 CFPB contracts valued at $244.5 million that, after undergoing cost modifications, grew to $262.1 million.

CFPB contracting officers followed Federal Acquisition Regulation and CFPB policies when awarding these contracts. However, for modifications, COs did not consistently conduct and document price reasonableness determinations and obtain the expected reviews by the CFPB's Legal Division. Providing clear guidance will promote consistent assessments of modification pricing and help the CFPB maximize value from contracting activities.

This report contains one recommendation.

The CFPB Can Improve Its Process for Onboarding Depository Institutions That Transition to Its Oversight

A key mission of the CFPB is overseeing compliance with federal consumer financial laws and regulations for depository institutions with over $10 billion in assets. From 2017 through 2023, 90 depository institutions crossed the $10 billion threshold and transitioned to the CFPB's oversight.

We found that the CFPB did not timely or effectively complete most of the transitions we reviewed, in some cases taking over a year to complete key onboarding steps. It also took varying approaches to coordinating with the prudential regulators. We attribute these issues to the CFPB not having established a program for onboarding depository institutions that transition to its oversight.

Our report contains recommendations to enhance the CFPB's onboarding of depository institutions.