Audit of the CFPB’s Consumer Response Operations
Pursuant to the Dodd-Frank Act, the CFPB’s Office of Consumer Response collects, monitors, and responds to consumer complaints on financial services and products. The CFPB uses these consumer complaints to help inform the agency’s supervision activities, enforce federal consumer financial laws, and write rules and regulations. With an increase in consumer complaints as a result of the COVID-19 pandemic, Consumer Response faces an operational risk with respect to the timeliness in which it can respond to consumer complaints. We plan to assess the effectiveness of the CFPB’s processes for reviewing and responding to consumer complaints.
Evaluation of the Paycheck Protection Program Liquidity Facility’s (PPPLF) Credit Extension Repayment and At-Risk Loan Monitoring Efforts
In response to the COVID-19 pandemic, the Board established the PPPLF to extend credit to financial institutions that originate loans through the U.S. Small Business Administration’s guaranteed Paycheck Protection Program (PPP), taking the PPP loans as collateral. The PPPLF, managed by the Federal Reserve Bank of Minneapolis and operated out of the 12 Federal Reserve Banks, distributed billions of dollars to eligible lenders. We will assess the effectiveness of internal controls to (1) determine lender eligibility, extend credit, and process repayments and (2) identify at-risk advances, handle instances of nonpayment, and detect and mitigate fraud. We also plan to assess the extent to which the Federal Reserve System coordinates with the U.S. Small Business Administration to determine lender eligibility, recover losses due to nonpayment, and detect and mitigate fraud.
Evaluation of the Federal Reserve System’s Loan Administration Processes for Its Main Street Lending Program (MSLP)
In response to the COVID-19 pandemic, the Board established the MSLP—composed of five different lending facilities—to facilitate lending to small and medium-sized for-profit and nonprofit organizations. Through the MSLP, the Federal Reserve Bank of Boston is responsible for administering the loans, including assessing overall credit risk and identifying substandard loans. We plan to assess the MSLP’s processes for loan administration, including the design and operating effectiveness of internal controls.
Monitoring of the Federal Reserve’s Lending Programs
In response to the economic effects of the coronavirus pandemic, the Federal Reserve recently announced that it would create new lending facilities to provide loans to employers, certain businesses, and communities across the country to support the U.S. economy. Specifically, the following programs have been created or are in development: the Main Street Lending Program, the Paycheck Protection Program Liquidity Facility, the Municipal Liquidity Facility, the Primary Market Corporate Credit Facility, and the Secondary Market Corporate Credit Facility. We are initiating an active monitoring effort of these programs to gain an understanding of operational, governance, reputational, and financial matters associated with them. Through this monitoring effort, we will refine our focus on the programs and identify areas for future audits or evaluations. Some of the topics we are considering include the design, operation, governance, and oversight of the lending programs; data collection and reporting associated with the programs; and the effect of the programs on the Board’s supervision and regulation activities.