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Sources and Uses of Data at the Bureau of Consumer Financial Protection

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Sources and Uses of Data at the Bureau of Consumer Financial Protection BUREAU OF CONSUMER FINANCIAL PROTECTION | SEPTEMBER 2018 Sources and Uses of Data at the Bureau of Consumer Financial Protection Table of Contents Table of Contents ...........................................................................................................1 1. Introduction .............................................................................................................4 2. Data governance at the Bureau ...........................................................................5 2.1 Bureau data governance policies............................................................... 6 2.2 Bureau data governance bodies ................................................................ 7 2.3 Data security and privacy .........................................................................11 2.4 External auditing ..................................................................................... 16 3. Sources of data.......................................................................................................21 3.1 Obtaining public data .............................................................................. 21 3.2 Data sharing from and with other government agencies and regulators22 3.3 Purchasing data from commercial vendors ............................................ 24 3.4 Collecting data from financial institutions ............................................. 26 3.5 Collecting data from consumers.............................................................. 28 4. Uses of data .............................................................................................................29 4.1 Public domain data .................................................................................. 29 4.2 Other agency data .................................................................................... 31 4.3 Commercial vendor data ......................................................................... 32 4.4 Financial institution data ........................................................................ 34 4.5 Consumer data ......................................................................................... 38 5. Data reused within the Bureau .........................................................................40 1 SOURCES AND USES OF DATA AT THE BUREAU OF CONSUMER FINANCIAL PROTECTION 5.1 Public domain data .................................................................................. 42 5.2 Other agency data .................................................................................... 42 5.3 Commercial vendor data ......................................................................... 42 5.4 Financial institution data ........................................................................ 43 5.5 Data collected for supervision, used for enforcement............................ 43 5.6 Consumer data ......................................................................................... 50 6. Description of core data assets and their uses .............................................52 7. Conclusion ..............................................................................................................59 List of Appendices........................................................................................................60 Appendix A: ...................................................................................................................61 Data governance policies and charters and data-sharing procedures............ 61 A1: Policy on information governance ............................................................. 62 A2: Public information intake & management policy exception .................... 78 A3: Low sensitivity information intake policy exception ................................ 81 A4: Local information storage policy exceptions ............................................ 84 A5: Voluntarily supplied contact information intake policy exception .......... 86 A6: Information sensitivity leveling standard ................................................. 89 A7: Data Governance Board Charter................................................................ 95 A8: Data Intake Group Charter ...................................................................... 100 A9: Data Release Group Charter .................................................................... 105 A10: Policy for the Sharing of Certain Confidential Supervisory Information with Employees in Research, Markets and Regulations ...................... 110 A11: Use of CII by RMR – Installment and Auto Title Lenders’ Financial Information ............................................................................................ 114 A12: Use of CII by RMR – Sm all-Dollar Lending...........................................116 A13: SEFL Integration 3.3 ...............................................................................118 2 SOURCES AND USES OF DATA AT THE BUREAU OF CONSUMER FINANCIAL PROTECTION Appendix B: .................................................................................................................152 List of data collections .................................................................................... 152 Bureau of Consumer Financial Protection – Data Inventory ....................... 152 Appendix C:..................................................................................................................189 List of MOUs ................................................................................................... 189 3 SOURCES AND USES OF DATA AT THE BUREAU OF CONSUMER FINANCIAL PROTECTION 1. Introduction The Bureau of Consumer Financial Protection (Bureau) was created by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). T he Dodd-Frank Act states that the Bureau “shall seek to implement and … enforce Federal consumer financial law consistently for the purpose of ensuring that all consumers have access to markets for consumer financial products and services and that [those markets] are fair, transparent, and competitive.”1 Data informs this work to a great extent. Outside of the Bureau’s Operations Division, three Divisions of the Bureau conduct most of the Bureau’s data-driven work: the Division of Supervision, Enforcement and Fair Lending (SEFL) is responsible for conducting supervisory, enforcement and fair lending activities; the Division of Research, Markets, and Regulations (RMR) is responsible for conducting research and monitoring the consumer financial products and services markets as well as developing, implementing, and assessing regulations; and the Division of Consumer Education and Engagement (CEE) is responsible for providing financial education to consumers and collecting, monitoring, and responding to consumer complaints regarding consumer financial products or services. To fulfill its statutory functions and obligations, the Bureau obtains data to inform its decisions. These activities include: . Writing rules, supervising companies, and enforcing the law . Taking consumer complaints . Providing financial education . Researching the consumer experience of using financial products, and . Monitoring financial markets for new risks to consumers The Bureau has data governance processes for each stage of the data lifecycle, including intake, management, publication, and disposition of data. This report describes those processes as well as what data the Bureau collects, where data come from, how data are used, and how data are 1 1 2 U.S.C. § 5511. 4 SOURCES AND USES OF DATA AT THE BUREAU OF CONSUMER FINANCIAL PROTECTION accessed and “reused” within the Bureau. 2 Appendix A provides copies of the governance documents, Appendix B lists the Bureau’s data assets subject to the limitations described below, and Appendix C lists the Bureau’s Memoranda of Understanding with other governmental and quasi-governmental agencies that address the sharing of data. 3 The Bureau intends to supplement this report with the text of its MOUs subject to obtaining the necessary approval of affected state and federal agencies. Appendix B does not cover Bureau data collections from consumers on a voluntary basis through focus groups, one-on-one interviews, user testing or small-scale informal surveys, except where such data collection took place in the context of developing disclosures in a rulemaking or potential rulemaking context. The Bureau is compiling information with respect to the data collections excluded from this report and will supplement the report by adding it to Appendix B. The Bureau also is compiling and will add to Appendix B information on the third- party costs associated with the purchase and/or collection of information by or on behalf of the Bureau to the extent possible. 2. Data governance at the Bureau T oday , data intake, management, and publication are governed by the Bureau’s Policy on Information Governance and related directives and operational charters, as part of the Bureau’s data governance program. 4 The Bureau’s Chief Information Officer (CIO)5 has delegated responsibility for this program to the Chief Data Officer (CDO), who generally oversees the Bureau’s data management. In this capacity, the CDO makes decisions regarding intake, management, disclosure, and disposition of Bureau data. The CDO reports to the Bureau’s CIO. The CDO’s Office includes a Data Policy team that develops policies, standards, and guidance to help the Bureau manage its data assets throughout the
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