Removing Barriers Blog

BCFP Moving Forward on Office of Cost Benefit Analysis
Posted November 26, 2018 by CUNA Advocacy

The Bureau is currently searching for an Assistant Director to lead a new Office of Cost Benefit Analysis (OCBA).  

Since taking over the BCFP, Acting Director Mulvaney has openly discussed the need for a cost-benefit focused office to ensure the Bureau is able to carry out its statutory mission.  Specifically, the Dodd-Frank Act requires the Bureau to consider “potential benefits and costs to consumers and covered persons, including the potential reduction of access by consumers to consumer financial products or services” prior to taking official actions. 

According to the Bureau’s website, the OCBA will be housed in the Director’s office and is “responsible for providing economic analysis, including cost-benefit analysis, and assisting in making decisions primarily in response to recommendations from Research, Markets and Regulations (RMR) and Supervision, Enforcement and Fair Lending (SEFL).”

CUNA has repeatedly called on the BCFP to conduct more cost-benefit research and analysis to inform its rulemakings and supervisory activities. In a white paper sent in response to the 2018 Call for Evidence, CUNA reiterated its long-held recommendation that the Bureau conduct full cost/benefit analyses prior to issuing rules impacting credit unions.  The creation and staffing of the OCBA is a positive step towards implementing CUNA’s recommendation.