The CFPB presented a report this past Monday trumpeting their accomplishments during the implementation period. And, they mention that they have a memorandum of understanding (MOU) in place with just about every transferor agency or other federal agency (i.e., the FTC) with whom they will be working.
Thanks to the misleadingly “open” design of the CFPB website, it is almost impossible to find their reports and documents and critical official bits and pieces—sprinkled as they are across the Blog, Press Center and a weird “Guidance” link. And, even then, I find I am often trolling through the Federal Register to find notices they have chosen not to provide links to yet.
That little diatribe aside, I have been looking and waiting for these MOUs because I am interested to see how detailed they are and what they reveal about the CFPB’s relationships with each agency. But, I have come up empty-handed so far—I cannot find them anywhere.
Here are the MOUs that are supposedly in place, and which I cannot find in any of the usual locations . . . please comment if you know where to find them, although I have a sneaking suspicion that the CFPB may just have decided to invoke some sort of governmental privilege and not make them public (do we have to resort to FOIA already?):
MOUs for the purpose of sharing non-public information in connection with their responsibilities related to or affecting the establishment of the Bureau with the OTS, OCC, NCUA, HUD, Federal Reserve Board, and FDIC.
Another MOU with the FFIEC for the purpose of safeguarding the confidentiality of information provided by the FFIEC to the CFPB.
One more MOU that permits the CFPB to access FinCEN’s BSA database and to obtain information such as money services business registration data and SARs submitted to FinCEN by financial institutions, which will be used to assist in supervision and enforcement.
And, MOUs put in place for the purpose of sharing information related to the agencies’ fair lending investigations, screening procedures, and investigative techniques with the Department of Justice, HUD, and the FTC.