Below is the text of Appleseed’s formal comments to the CFPB “enthusiastically” supporting the External Engagement program as critical component of pro-active support of consumer protection. For further information, please contact Annette LoVoi, Appleseed’s Director of Financial Access and Asset Building.
May 29, 2018
Office of the Executive Secretary
Consumer Financial Protection CFPB
1700 G Street NW
Washington, DC 20552
Via email: FederalRegisterComments@cfpb.gov
RE: Request for Information, CFPB External Engagement/Docket No. CFPB-2018-0005
Dear Ms. Jackson,
Appleseed wishes to provide the following comment in response to the Request for Information (RFI) regarding the Consumer Financial Protection Bureau’s (CFPB) External Engagements.
Appleseed has been honored to support the Consumer Bureau’s robust external engagement program and participate in meetings and events over the past six years.
Appleseed and some of our centers have participated in the CFPB’s advisory board meetings, field hearings, town-halls, meetings with stakeholders, speaking engagements, and conferences. We have directed individuals to the CFPB consumer complaints system and its “Tell Your Story” website. We know first-hand the power of each of these external engagement tools and we whole-heartedly urge and endorse their continuation and expansion:
“External engagement”—open and ongoing, robust communication with external stakeholders—is vital to all the functions that Congress assigned the CFPB: supervision, enforcement, financial education, addressing consumer complaints, monitoring markets to identify risks to consumers, and issuing rules to implement consumer protection law.
Appleseed enthusiastically supports such engagement, and especially encourages the CFPB to continue the practice of face to face conversations by the director and his or her team with individual consumers. Individuals can convey to the CFPB leadership where they experience financial difficulties, how they are treated, and what remedies actually work for them. We urge CFPB leadership, as well as staff across all levels of the agency, to dedicate time to engaging directly with consumers and their representatives, as well as other stakeholders.
Robust external engagement ensures that the CFPB can share information with consumers, industry participants, and the wide range of other entities interested in and affected by the CFPB’s actions. Moreover, external engagement ensures that the CFPB’s policymakers, consumer educators, attorneys, examiners, and other staff have the information they need to understand and appropriately address consumers’ needs and experiences. Any engagement forum, from a one-on-one conversation to a large town-hall meeting to a social media exchange, can provide the CFPB with invaluable information about how the markets for consumer
financial products and services operate and the risks that consumers may face, and this information is vital for the CFPB to develop and target its initiatives appropriately.
We urge continuation of the external engagement practices of the CFPB’s first six years:
Public engagement has been and should remain a hallmark of the CFPB. Congress created this agency to protect consumers, and this consumer protection mandate requires a pro-active posture of public engagement.
Director of Financial Access and Asset Building
1 Consumer Complaint Database, Consumer Financial Protection CFPB (website visited April 26, 2018)