A Look at BCFP’s Newly Re-Formed Consumer Advisory Board

Inside Subprime: Oct 3, 2018

By Aubrey Sitler

The Bureau for Consumer Financial Protection (BCFP – formerly known as the Consumer Financial Protection Bureau, or CFPB) announced the new membership of its Consumer Advisory Board (CAB) last month. While this may sound promising, a deeper look at on who’s on the membership list, as well as a bit of historical context, may indicate otherwise.

Let’s start from the beginning – or at least, the beginning of the summer.

In June of 2018, all advisory boards including the CAB were disbanded by Acting Director Mick Mulvaney. American Banker reported at the time that current advisory board members were informed of this decision by Anthony Welcher, the BCFP’s policy advisor for external affairs, who told them on a conference call: “We’ve decided we’re going to start the advisory groups with new membership, to bring in these new perspectives and new dialogue. We want more diverse voices and we want to bring people in from larger-scale organizations, larger-scale opportunities in the communities to hear about processes we may be going through.”

All members of 3 BCFP advisory boards – the CAB, the Community Bank Advisory Board, and the Credit Union Advisory Board – were later informed by email that they had been terminated and were not eligible to re-apply for the new membership positions. (However, it is worth noting that Brent Neiser, Senior Director of Strategic Programs and Alliances at the National Endowment for Financial Education was re-appointed to this new membership group.)

This move to dismantle the current advisory board membership was troubling to many who see Mulvaney as trying to undermine the BCFP’s statutory requirements to convene the CAB, which is designated to advise the Bureau on the trends, practices, products, and rising concerns in the consumer financial services industry.

The first noticeable difference in the new CAB membership is its size: the formerly 25-member board has been stripped by nearly two-thirds, with only 9 members on its newly instated team.

The new CAB includes representatives from:

  • a consumer advocacy group
  • a tech-based loan servicer
  • a mobile investing app
  • a no-fee, no-credit-score-required credit card provider
  • a loan provider
  • a university president who also has a background in investment management consulting
  • a private, nonprofit, nonpartisan financial literacy foundation
  • an employee income optimization service provider and
  • a non-profit micro-lender

As noticed and analyzed by InsideARM, none of the new members represents the accounts receivable management (ARM) (i.e., debt collection), industry – an industry that has struggled to find representation on the CAB since its founding.  Players who are engaged in innovating new solutions are necessary to represent the industry’s voice on the board and advocate for new solutions with peer companies. Without that representation, how can the BCFP ensure that it understands and is responsive to this industry that is so integral to any consumer financial protection efforts?

Only time will tell the direction in which this newly convened group will focus (or not) its attention and efforts.

For information on predatory payday loans check out all of our state-by-state Subprime Reports.

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