Overview
Title
Advisory Committees Solicitation of Applications for Membership
Agencies
ELI5 AI
The Consumer Financial Protection Bureau is looking for people to join special groups that help them make rules about money. They want a variety of people, like those who help others with money problems or are experts in money, to apply.
Summary AI
The Consumer Financial Protection Bureau is seeking applications for membership on its advisory committees, which include the Consumer Advisory Board, Community Bank Advisory Council, Credit Union Advisory Council, and Academic Research Council. These committees consist of experts from various fields like consumer protection, financial services, and economics to advise the bureau on consumer financial markets. The membership, which usually lasts two years, requires diverse representation of communities and interests, including those underserved. Applications are accepted online by February 24, 2021, and should include a cover letter, résumé, recommendation letter, and completed questionnaire. The Bureau aims to announce the selected new members in late summer 2021.
Abstract
Pursuant to the authorities given to the Director of the Bureau of Consumer Financial Protection (Bureau) under the Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) Director Kraninger invites the public to apply for membership for appointment to its Consumer Advisory Board (CAB), Community Bank Advisory Council (CBAC), Credit Union Advisory Council (CUAC), and Academic Research Council (ARC), (collectively, advisory committees). Membership of the advisory committees includes representatives of consumers, diverse communities, the financial services industry, academics, and economists. Appointments to the committees are generally for two years. However, the Director may amend the respective committee charters from time to time during the charter terms, as the Director deems necessary to accomplish the purpose of the committees. The Bureau expects to announce the selection of new members in late-summer 2021.
Keywords AI
Sources
AnalysisAI
The document from the Consumer Financial Protection Bureau (CFPB) outlines an invitation for the public to apply for membership on its advisory committees, namely the Consumer Advisory Board, Community Bank Advisory Council, Credit Union Advisory Council, and Academic Research Council. These committees are designed to bring together a diverse array of experts, including representatives from consumers, community leaders, the financial services industry, academics, and economists. The purpose is to provide advice and consultation to the CFPB regarding its work in consumer financial markets. Committee appointments typically last two years.
Significant Issues and Concerns
One of the major issues with the document is the lack of clarity regarding the number of available positions on each advisory committee. This could create misunderstanding regarding the competitiveness and chances of selection for potential applicants. Additionally, the requirement for a recommendation letter as part of the application process may inadvertently favor individuals with stronger professional networks, potentially disadvantaging those with fewer connections or resources.
The document also excludes certain categories of individuals from applying, such as federally registered lobbyists, convicted felons, and current elected officials. However, it does not offer an explanation for these exclusions, which might be perceived as a lack of transparency and could raise questions among applicants.
Furthermore, the complexity of the application process, which includes multiple components like a cover letter, résumé, recommendation letter, and questionnaire, may present challenges for individuals from underserved communities seeking to apply. While the CFPB emphasizes the importance of diversity, the document does not provide specific measures or metrics to ensure the achievement of such diversity beyond encouraging applications from diverse groups.
Lastly, the document does not disclose details regarding the selection process, leaving applicants wondering how their submissions will be evaluated. This lack of transparency could prompt concerns about fairness and impartiality in the selection process.
Impact on the Public
Broadly speaking, this call for applications to advisory committees represents an opportunity for the public to get involved in the regulatory processes of consumer financial protection. By including a variety of voices, the CFPB aims to ensure that its activities and policies are informed by diverse perspectives, reflecting the needs and interests of all stakeholders in consumer financial markets.
Impact on Specific Stakeholders
For experts and professionals in consumer protection, financial services, and related fields, this document opens up a chance to contribute directly to the regulatory environment and influence how the CFPB operates and prioritizes tasks. Stakeholders from underserved communities, such as representatives of minority groups or those significantly impacted by higher-priced mortgage loans, are particularly encouraged to apply. This aligns with the CFPB's goals to include diverse perspectives, though it may also be the very group most challenged by the detailed application requirements.
On the negative side, the potentially exclusionary application process might marginalize individuals who could provide valuable insights but lack the means or networks to navigate the rigorous application demands. The absence of clear selection criteria further complicates this aspect by leaving candidates uncertain about the fairness of their chances.
In conclusion, the call for applications to the CFPB's advisory committees highlights an essential aspect of public participation in regulatory affairs but poses challenges in terms of accessibility and transparency that need to be addressed to fully realize an inclusive approach.
Financial Assessment
In this Federal Register document, the focus is on the solicitation of applications for membership on various advisory committees of the Consumer Financial Protection Bureau (CFPB). The document makes specific financial references regarding the eligibility criteria for committee membership, but it does not outline specific spending or appropriations related to these committees.
Financial References
The document includes two main financial thresholds concerning the eligibility for membership on the advisory committees:
Banks and Thrifts: Membership is restricted to employees of banks and thrifts with total assets of $10 billion or less that are not affiliates of depository institutions or community banks with total assets exceeding $10 billion. This financial criterion sets a clear boundary for participation, ensuring that the advisory committees are composed of representatives from smaller and potentially less influential financial institutions.
Credit Unions: Similarly, membership is limited to employees of credit unions with total assets of $10 billion or less that are not tied to larger depository institutions or credit unions with assets of more than $10 billion. This mirrors the financial limitations placed on banks and thrifts, focusing the advisory committee's representation on smaller-scale entities.
Relating Financial References to Identified Issues
These financial thresholds directly address several issues related to the composition and inclusivity of the advisory committees:
Representation of Diverse Economic Entities: By capping the asset size at $10 billion, the CFPB aims to include a diverse range of financial organizations that often deal directly with local communities, as smaller institutions are more likely to serve specific regional needs or underserved markets. This could support the document's broader goal of ensuring diverse viewpoints and inclusivity in advisory roles.
Potential Exclusion and Barriers: While the intention is to gather diverse insights, this financial criterion may inadvertently exclude larger financial institutions' representatives, who also have comprehensive experiences and insights. This exclusion aligns with one of the identified issues about the lack of transparency in the selection process, as it could lead to questions regarding whether asset size alone is an adequate measure of an institution's relevance or insightfulness.
Complex Application Requirements: The financial limitations set by the CFPB could potentially simplify the application evaluation process by narrowing the eligibility pool based on measurable criteria. However, the detailed requirements and exclusions listed might present challenges, especially to qualified representatives from smaller institutions or communities that may lack the resources or networks typical of larger institutions.
In summary, while the financial thresholds aim to provide a level playing field for smaller institutions, they can also be seen as a double-edged sword, potentially limiting broader insights from larger entities. The measures reflect an intent to democratize advisory input but would benefit from clarity on how these financial limits contribute to the agency's goals and the overall selection and representation process.
Issues
• The document does not specify the number of positions available on each advisory committee, which could lead to ambiguity regarding the chances of selection for applicants.
• The application procedure's requirement for a 'recommendation letter from a third party' may favor individuals with professional networks, potentially disadvantaging qualified individuals without such connections.
• The exclusion of certain categories of individuals - such as federally registered lobbyists, convicted felons, or current elected officials - from applying to these advisory committees is stated, but the rationale behind these exclusions is not provided, which could be seen as lacking transparency.
• The application requirements are quite detailed and might be complex for some potential applicants, particularly those from underserved communities or those without access to sufficient resources or guidance in application preparation.
• The document suggests diversity and representation as important but does not provide concrete measures or metrics on how this will be achieved beyond encouraging applications from diverse groups.
• There is no mention of the selection process beyond application submission, leaving the method for evaluating and selecting candidates unclear, which might lead to questions about fairness or transparency.