Today, Consumer Financial Protection Bureau (Bureau) Director Kathleen L. Kraninger made the following statement regarding her second-year anniversary leading the Bureau:
“In these challenging times, I’m proud of the work that the Bureau has undertaken to protect consumers during the pandemic,” said CFPB Director Kraninger. “We have a dedicated workforce that has been focused on carrying out our mission and adapting to the current environment. For example, we have altered the way that we conduct examinations to protect our workforce as they work to protect consumers in the marketplace. We will continue to use all of our tools to prevent consumer harm through education, supervision of financial markets, development of regulation, and enforcement of the law against bad actors.”
In the second year under Director Kraninger’s leadership, the Bureau’s work has included:
Informing Consumers of their options during the pandemic and helping companies focus resources on providing assistance
- Launched a federal interagency housing website with the U.S. Department of Agriculture, U.S. Department of Housing and Urban Development, U.S. Department of Veterans Affairs and Federal Housing Finance Agency. For consumers who are concerned about how they will pay their mortgage or rent because of the coronavirus, the website is a one-stop-shop to find accurate information about relief options available to them—especially those under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
- Rapidly responded to the COVID-19 pandemic by producing a series of tools (more than 70 blogs, web pages, and videos) on pandemic-related consumer education materials, many of which are available in multiple languages.
- Created a webpage of pandemic-related resources which is continually updated. Topics covered include mortgages, credit reporting, debt collection, student loans, frauds and scams, and managing your finances.
- Since the pandemic began, more than 4 million users accessed the pandemic-specific resources on the web, with another 7.3 million web users accessing the Bureau’s other educational resources in FY20.
- Created and implemented a new, targeted supervisory approach, known as Prioritized Assessments, which consists of high-level inquiries designed to obtain information from entities to assess the impacts on consumer financial product markets due to pandemic-related issues.
- Provided temporary flexibility to enable financial companies to work with customers in need as they responded to the pandemic by postponing some data collections from companies on Bureau-related rules to allow the companies to focus on responding to consumers in need.
- Organized outreach and engagements with all stakeholders and garnered significant and useful feedback on the impact of the pandemic on consumers and financial markets.
- The Bureau’s advisory committees held public meetings, including a combined advisory committee meeting via conference call with the Consumer Advisory Board, Community Bank Advisory Council, Credit Union Advisory Council, and Academic Research Council, to discuss the impact of the pandemic on consumers and the financial marketplace, in addition to other topics.
- Facilitated numerous virtual engagements with external stakeholders including, most notably, Director speeches at virtual conferences, townhalls, meetings, the Cost-Benefit Analysis symposium, and the advisory committee spring and fall meetings and on-boarded new advisory committee members, as well as similar outreach opportunities that yielded significant feedback and recommendations on the pandemic.
Vigorously enforcing the law against bad actors to help the Bureau reach the second highest number of public enforcement actions in a year
- To date in 2020, the Bureau has brought 42 public enforcement actions and is on target to exceed the second highest number of public enforcement actions filed–since the Bureau’s inception–by the end of this year. The filing of several more public enforcement actions by the end of the year is expected.
- The Bureau is currently litigating nearly 30 cases—which is also among the largest litigation dockets in its history. Among the Bureau’s current litigations are two very substantial cases involving Ocwen Financial Corporation —one of the leading non-bank mortgage servicers in the country—and Navient Solutions—one of the nation’s largest servicers of federal and private student loans.
- The Bureau continues to survey the market in real time to address law violators. Among other things, it reviews its complaint database, meets and coordinates with other state and federal agencies, monitors news reports and legal filings, and reviews whistleblower tips to uncover potential malfeasance.
- Under Director Kraninger’s tenure, the Bureau’s public enforcement actions have resulted in orders requiring over $1.45 billion in total consumer relief as well as over $270 million in civil money penalties. To date in 2020, the Bureau’s public enforcement actions have resulted in orders requiring nearly $670 million in total consumer relief and over $90 million in civil money penalties. By the end of the year, additional actions will increase these amounts potentially significantly. This would put the Bureau at near-historic highs of both the number of public enforcement actions and associated recoveries. These actions have also resulted in a wide range of injunctive relief designed to stop unlawful conduct and prevent future violations—including in some instances banning future participation in the market.
- In the fair lending arena, the Bureau:
- Filed a lawsuit against a company alleging that it engaged in redlining and discouragement.
- Issued a consent order against a bank, finding that it reported inaccurate Home Mortgage Disclosure Act data.
- Has a number of ongoing fair lending investigations and anticipates opening additional investigations.
- In actions against banks within our authority, the Bureau:
- Filed a lawsuit against Fifth Third National Bank Association for allegedly opening unauthorized deposit and credit-card accounts
- Filed a lawsuit against a Citizens Bank, N.A. for allegedly failing to properly manage and respond to consumers’ credit card disputes and fraud claims.
- Issued a consent order against T.D. Bank., N.A. regarding its marketing and sale of its optional overdraft service. The order requires it to pay about $97 million in restitution and pay a $25 million civil money penalty.
- As part of a sweep to address violations of the Remittance Transfer Rule, the Bureau:
- Filed two additional settlements with two companies and their subsidiaries as part of its sweep of enforcement actions to address violations of the Remittance Transfer Rule. The consent orders require the companies to pay nearly $2 million in civil money penalties and impose requirements to prevent future violations. One company and its subsidiaries must also pay consumer redress.
- As part of a sweep to address violations of the Military Lending Act (MLA), the Bureau:
- Filed a lawsuit against LendUp Loans, LLC, an online lender that allegedly violated the MLA by extending loans with an annualized percentage rate that exceeds the MLA’s 36% cap, loans that require borrowers to submit to arbitration, and failing to make certain loan disclosures.
- In actions against nonbank market entities within our authority, the Bureau:
- Filed a proposed judgment and order against the largest non-bank servicer in the country, Nationstar Mortgage LLC. The Bureau’s action was part of a coordinated effort between the Bureau, a multistate group of state attorneys general, and state bank regulators. The Bureau alleged that Nationstar violated multiple federal consumer financial laws, causing substantial harm to the borrowers whose mortgage loans it serviced, including distressed homeowners. The proposed judgment and order, if entered by the court, would require Nationstar to pay approximately $73 million in redress to more than 40,000 harmed borrowers. It would also require Nationstar to pay a $1.5 million civil penalty to the Bureau.
- Issued a consent order against a company, finding that it and its agents engaged in unfair and deceptive acts and practices in its servicing of auto loans. The consent order requires the company to provide up to $1 million of cash redress, credit any outstanding account charges associated with a wrongful repossession, and to pay a civil money penalty of $4 million.
- Filed and then settled against a company and its subsidiaries—which together comprise the largest debt collector and debt buyer in the United States. The Bureau alleged that they violated the terms of a prior Bureau consent order and again engaged in unlawful debt collection activities. The settlement requires the and its subsidiaries to pay $79,308.81 in redress to consumers and a $15 million civil money penalty.
- In an effort to protect servicemembers, the Bureau:
- Engaged in a sweep of investigations of multiple mortgage companies that used deceptive mailers to advertise VA-guaranteed mortgages, which yielded nine public enforcement actions. Through these nine settlements, the Bureau obtained more than $4.4 million in civil money penalties, and imposed strong requirements to prevent future violations. The consent orders also impose substantial prohibitions and enhanced disclosure requirements that each company must follow.
- To protect students, the Bureau:
- Filed a proposed stipulated judgment against PEAKS, a group of trusts that owned and managed private loans for students at ITT Technical Institute. The Bureau alleged that PEAKS knew or was reckless in not knowing that many student borrowers did not understand the terms and conditions of those loans and could not afford them, or in some cases, did not even know they had them. If entered by the court, the proposed stipulated judgment would require PEAKS to stop collecting on all outstanding PEAKS loans, discharge all outstanding PEAKS loans, and ask all consumer reporting agencies to which PEAKS furnished information to delete information relating to PEAKS loans. The total amount of loan forgiveness is currently estimated to be $330 million, which will be provided to the approximately 35,000 borrowers with outstanding principal balances on their PEAKS loans.
- Is preparing for trial in its lawsuit against Navient Corporation and its subsidiaries, Navient Solutions, Inc., and Pioneer Credit Recovery, Inc. The Bureau has alleged that Navient Solutions and Navient Corporation steered borrowers toward repayment plans that resulted in borrowers paying more than other options; misreported to credit reporting agencies that severely and permanently disabled borrowers who had loans discharged under a federal program had defaulted on the loans when they had not; deceived private student loan borrowers about requirements to release their co-signer from the loan; and repeatedly incorrectly applied or misallocated borrower payments to their accounts. The Bureau has also alleged that Pioneer and Navient Corporation misled borrowers about the effect of rehabilitation on their credit reports and the collection fees that would be forgiven in the federal loan rehabilitation program.
- In numerous other actions across the markets over which it has enforcement jurisdiction, the Bureau took action to address law violations in connection with various other consumer financial products and services, including action to stop law violations related to auto servicing, student finance, debt collection, debt relief, auto-title lending, credit repair, and high-interest loans to veterans. In doing so, the Bureau partnered with a number of state agencies, including the Arkansas, Massachusetts, and New York attorneys general.
Promoting access to financial products for all consumers
- Issued a Request for Information (RFI) seeking comments and information to identify opportunities to prevent credit discrimination, encourage responsible innovation, promote fair, equitable, and nondiscriminatory access to credit, address potential regulatory uncertainty, and develop viable solutions to regulatory compliance challenges under the Equal Credit Opportunity Act and Regulation B. Among the topics included in the RFI are how to better protect consumers with limited English proficiency as well as applicants who derive income from any public assistance program.
- The Bureau, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the National Credit Union Administration issued a joint statement on the use of alternative data in underwriting by banks, credit unions, and non-bank financial firms. The purpose of the statement was to provide guidance on the use of alternative data in underwriting and, to the extent firms are using or contemplating using alternative data, to encourage responsible use of such data.
- Continues to meet with and engage organizations representing limited English proficiency consumers to identify concerns they face when seeking financial information in multiple languages. As a result of these engagements, the Bureau produced most of its pandemic education content in multiple languages, including videos and online resources.
Facilitating compliance by providing clear rules of the road through rulemaking
- Issued an advance notice of proposed rulemaking (ANPR) to seek input on how to most efficiently and effectively develop regulations to implement section 1033 of the Dodd-Frank Act, which provides for consumer access to financial records. The consumer rights described in section 1033 affect a wide variety of consumer financial products that millions of Americans use regularly. The Bureau also took the first steps toward developing rules to implement Section 1033, ten years after the passage of the Dodd-Frank Act. While issuing an ANPR is an optional step in the rulemaking process, the Bureau is committed to ensuring transparent and deliberate rulemaking processes.
- Released its Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 of the Dodd-Frank Act governing small business lending data collection and reporting. The Bureau convened a Small Business Advocacy Review panel in October 2020. The panel will prepare a report that examines the impact of the potential rule on small businesses. The report, along with feedback received from small businesses, will be considered by the Bureau in its rulemaking to implement Section 1071.
- Issued a final rule amending its Disclosure of Records and Information Regulation, seeking to balance concerns regarding the Bureau’s need to protect confidential and investigative information against the need to use and disclose certain information in the course of the Bureau’s work or that of other agencies.
- The Bureau issued multiple final rules in calendar year 2020 as part of the priority to provide clear rules of the road. The rules included:
- Payday, Vehicle Title, and Certain High-Cost Installment Loans
- The final rule concerning small dollar lending rescinds the mandatory underwriting provisions of the 2017 rule while maintaining consumer access to credit and competition in the marketplace. The Bureau’s action will help to ensure the continued availability of small dollar lending products for consumers who demand them, including those who may have a particular need for such products as a result of the current pandemic.
- Remittance Transfers Under the Electronic Fund Transfer Act
- The final rule allows certain banks and credit unions to continue to provide estimates of the exchange rate and certain fees under certain conditions. This could preserve consumers’ ability to send remittances from their bank accounts to certain countries or recipient institutions. The final rule will also reduce burden on over 400 banks and almost 250 credit unions that send a relatively small number of remittances.
- Home Mortgage Disclosure Act
- The final rule increases the permanent threshold for collecting and reporting data about closed-end mortgage loans and open-end lines of credit. Once effective, the rule will reduce regulatory burden on smaller institutions to help those institutions to focus on responding to consumers in need now and in the longer term.
- Debt collection rule to clarify protections Under the Fair Debt Collection Practices Act
- The final rule restates and clarifies prohibitions on harassment and abuse, false or misleading representations, and unfair practices by debt collectors when collecting consumer debt. The rule focuses on debt collection communications and gives consumers more control over how often and through what means debt collectors can communicate with them regarding their debts. The rule also clarifies how the protections of the Fair Debt Collection Practices Act, which was passed in 1977, apply to newer communication technologies, such as email, text messages and social media, adding protections for consumers when debt collectors contact them through these technologies.
- General Qualified Mortgage (QM)
- The final rule replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43% with a limit based on the loan’s pricing. In adopting a price-based approach to replace the specific DTI limit for General QM loans, the Bureau determined that a loan’s price is a strong indicator of a consumer’s ability to repay and is a more holistic and flexible measure of a consumer’s ability to repay than DTI alone.
- Seasoned QMs
- The final rule creates a new category of Seasoned QMs for first-lien, fixed-rate covered transactions that have met certain performance requirements, are held in portfolio by the originating creditor or first purchaser for a 36-month period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements.
- Established Taskforce on Federal Consumer Financial Law on January 9, 2020, which is intended to examine the existing legal and regulatory environment facing consumers and financial services providers. The Taskforce is an independent body within the Bureau and reports to the Director. At the conclusion of its one-year term, the Taskforce will deliver a report of recommendations for ways to improve and strengthen consumer financial laws and regulations to the Director.
Creating a culture of compliance
- Institutions paid more than $80 million in restitution in connection with supervisory activities to more than 666,000 consumers in FY 2020. During this same period Supervision issued 457 matters requiring attention to supervised entities setting forth appropriate corrective actions and promoting a culture of compliance; among which include:
- In FY 2020 the Bureau started 104 supervisory exams/reviews at supervised entities and completed 140 supervisory exams/reviews at supervised entities.
- The Bureau began implementation of a supervisory program to review information technology and IT controls for their impact on compliance with federal consumer financial law.
- Published three issues of Supervisory Highlights in FY 2020:
- Issue 20: A special edition of Supervisory Highlights covering consumer reporting supervisory observations at furnishers and consumer reporting agencies.
- Issue 21: Covering supervisory findings in the areas of debt collection, mortgage servicing, payday lending, and student loan servicing.
- Issue 22: Covering supervisory findings in the areas of consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending.
- Implemented a comprehensive policy to permit entities to terminate Bureau consent orders.
- Issued a compliance bulletin titled Handling of Information and Documents during Mortgage Servicing Transfers, to provide guidance to residential mortgage servicers regarding the transfer of mortgage loans.
- Instituted a post-commissioning specialization program that deepens examiner expertise in fair lending, mortgage origination, mortgage servicing, and coaching/training.
- Issued its final Advisory Opinions Policy to publicly address regulatory uncertainty in the Bureau’s existing regulations and provide guidance to entities on outstanding regulatory uncertainty. In addition to the final Policy, the Bureau issued two advisory opinions. The first one regarded earned wage access products to facilitate earlier access to wages at no cost to employees. The second rule clarified requirements for certain education loan products that refinance or consolidate a consumer’s pre-existing loans.
Educating and empowering consumers to make better informed financial decisions
- Expanded the Start Small, Save Up initiative to encourage consumers to build emergency savings and increase opportunities for more consumers to save.
- Offered training to assist librarians at more than 100 libraries registered to receive information that can help make their libraries a “go-to” financial education resource in the community.
- The Bureau’s network of financial education practitioners grew from 8,200 to 21,000, helping improve the connectedness of the financial education field to the Bureau and leveraging financial education practitioners to reach more people with Bureau resources.
- The Director was the featured author for a guest post on Sesame Workshop’s website. The post is titled “Helping your child’s money skills grow.” This was an opportunity to highlight the Bureau’s Money as You Grow consumer education resources to help parents and caregivers teach children about basic financial skills.
- Launched ready-to-use classroom activities for high/middle/elementary school teachers and more than 50,700 teachers were reached with activities for classroom use. These resources have become critical as the need has increased significantly during the pandemic as parents are home schooling their children and teachers are looking for virtual resources.
- Launched a new web tool on paying for college called Your Financial Path to Graduation to help students evaluate financial aid offers and provide action steps to prepare to pay for higher education.
- Expanded reach to consumers and those who serve them through the Financial Intuition podcast series that covers financial topics for students and young consumers to manage money, save and pay for college, and repay student debt.
- Expanded the Misadventures in Money Management series to include a military family module and produced the Your Money Your Goals Military Companion Guide.
- Launched the Elder Fraud Prevention and Response Networks Development Guide, an online resource to help communities form networks to increase their capacity to prevent and respond to elder financial abuse. The guide offers planning tools, templates, and exercises to help communities create a collaborative network to fight elder fraud or refresh or expand an existing network.
- Educated more than 6,000 aging services, financial institution, law enforcement, and other professionals about the value of, and resources for, elder fraud prevention and response networks.
- Educated more than 5,000 aging services professionals about fiduciary roles and resources for consumers through the Managing Someone Else’s Money guides.
- As part of the Your Money Your Goals (YMYG) Program, the Bureau facilitated training of more than 4,400 staff in intermediary organizations who work directly with lower-income consumers, providing information and action steps in money management that can be shared with the people they serve. Survey findings showed that 90% more staff felt highly confident in their ability to support clients on finances. Additionally, more than 380,000 YMYG consumer-facing print publications were ordered by the public.
- Drawing from its credit research and consumer education programs, the Bureau worked with six urban and rural communities to help consumers build a positive credit history and protect their credit when facing financial challenges.
- Reached diverse coalitions across the country during various town halls and roundtables including the Director at the National Diversity Coalition’s town hall and virtual coffee break, which were attended by hundreds of diverse community and industry leaders.
Informing the Bureau’s work through the use of research
- In its most productive period to date for publishing research, the Bureau released reports on a variety of topics, most notably two special issue Data Points regarding the effects of the pandemic on consumer financial markets. The Bureau’s reports and publications were cited in over 200 publications. Among the research includes:
- Market Snapshot: Background Screening Reports
- Data Point: Servicer Size in the Mortgage Market
- Data Point: Borrower Experiences on Income Driven Repayment
- Quarterly Consumer Credit Trends (qCCT): Public Records 2
- Market Snapshot: First-time Homebuyers
- Data Point: Small business lending and the Great Recession
- Quarterly Consumer Credit Trends (qCCT): Recent Trends in Debt Settlement and Credit Counseling
- Data Point: Perceived Financial Preparedness, Saving Habits, and Financial Security
- Data Point: Special issue brief: The early effects of the pandemic on consumer credit
- Data Point: An updated review of the new and revised data points in HMDA: Further observations using the 2019 HMDA data
- Data Point: Insights from the Making Ends Meet Survey
- Data Point: 2019 mortgage market activity and trends
- Data Point: The early effects of the pandemic on credit applications
Receiving consumer complaints, sharing information with interagency partners, and taking action as appropriate
- Handled record complaint volume in calendar year 2020, despite the changes in operations brought by the pandemic and stay-at-home orders.
- Fielded more than 500,000 complaints through December 2020 compared to 332,000 in the same period in 2019, an overall increase of approximately 51%.
- Received its 2.5 millionth consumer complaint in October 2020.
- Supported more than 5,800 companies responding to complaints, answering more than 2,500 questions from company users and their trade associations, responding within an average of 0.4 days.
- Launched the Borrower Protection Program, a new joint initiative with the FHFA that includes making Bureau complaint information and future analytical tools available to FHFA via a secure electronic interface.
- The Bureau and the Department of Education signed a new memorandum (MOU) of understanding to share complaint information from borrowers and meet quarterly to discuss observations about the nature of complaints received, characteristics of borrowers, and available information about resolution of complaints. The MOU also provides for the sharing of complaint data analysis, recommendations, and analytical tools.
- The Bureau released its yearly report analyzing student loan complaints submitted by consumers from September 1, 2019, through August 31, 2020.
Promoting innovation to support consumers
- Granted seven applications in 2020 under its innovations policies announce in 2019.
- Issued two No Action Letter (NAL) templates under its innovation policies to provide increased regulatory certainty. Using the first template, mortgage servicers seeking to assist struggling borrowers to avoid foreclosure and engage in loss mitigation efforts would be able to apply for their own NAL. To further competition in the small-dollar lending space and facilitate robust competition that fosters access to credit, the Bureau also approved a second template that insured depository institutions can use to apply for a NAL covering their small-dollar credit products. The templates include important protections for consumers who seek small-dollar loan products.
- Hosted its first Tech Sprint to improve consumer disclosures. The hackathon-style event generated innovations to improve adverse action notices issued pursuant to the Equal Credit Opportunity Act and the Fair Credit Reporting Act. Thirteen teams, made up of those in industry, advocacy, academia, and other fields, developed and demonstrated new disclosures, modeling methods, and other improvements that have the potential to make disclosures more fair, informative, or accurate. This was the first Tech Sprint hosted by a federal financial regulator.
- Hosted the first joint innovation office hours with the Utah Attorney General, the Colorado Attorney General, and the Office of the Comptroller of the Currency as part of the American Consumer Financial Innovation Network (ACFIN), which now has 21 members. The Bureau founded ACFIN to increase coordination between state and federal regulators on the topic of consumer financial innovation. Office hours, and ACFIN’s growing membership, demonstrate the broad coalition of regulators devoted to furthering innovation that the Bureau has assembled.
Enhanced inter-agency coordination
- Worked collaboratively with other Federal Financial Institutions Examination Council’s (FFIEC) member agencies to respond to challenges posed to consumers by the pandemic including the issuance of guidance to financial institutions on prudent risk management and consumer protection principles for financial institutions to consider while working with borrowers as initial pandemic-related loan accommodation periods end.
- Worked in partnership with the Internal Revenue Service (IRS) to help the estimated 9 million non-filers collect their Economic Impact Payments (EIP). The Bureau created and widely distributed a guide to assist the intermediaries who work with and council this hard-to-reach population.
- Hosted three Director-level listening sessions with direct service providers and civil rights leaders to hear about the experiences of economically vulnerable consumers in April and May 2020 affected by the pandemic and worked to better assist struggling homeowners with their CARES Act protections, and led multiple interagency discussions including with IRS and Treasury staff about the Bureau’s outreach plan and strategies to amplify on the EIP effort.
- Hosted a student loan symposium with Federal Student Aid’s student loan ombudsman, the Conference of State Banking Supervisors, a national consumer advocacy group and an industry trade association.
Promoting a more inclusive, effective and efficient organization
###The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by regularly identifying and addressing outdated, unnecessary, or unduly burdensome regulations, by making rules more effective, by consistently enforcing federal consumer financial law, and by empowering consumers to take more control over their economic lives. For more information, visit consumerfinance.gov.
- Built a diverse and inclusive workforce. Our workforce consists of 50% women and 41% Minority employees. The Bureau’s leadership team is 49% women and 36% minorities.
- Launched the Mentoring for Success program to enhance professional development. It includes: 35 matched mentor/protégé pairs that meet regularly; a leadership speaker series; and group discussions on career development topics.
- The Bureau’s mission is best accomplished with a diverse and inclusive workforce which reflects the nation’s diversity. The Bureau continues to promote diversity and inclusion by promoting comprehensive diversity and inclusion trainings and dialogues.
- Participated in High School Scholar Internship Program (HSSIP). The Bureau partnered with the Office of the Comptroller of the Currency (OCC), the District of Columbia government’s Department of Employment Services (DOES) and the Marion S. Barry Summer Youth Employment Program (SYEP) and hosted 10 interns from Washington D.C. High Schools. The interns were exposure to careers in public service, particularly in the field of consumer financial protection.
- Completed the renovation and relocation of all Washington, DC-based staff from two office buildings into one to increase the effectiveness of the organization and to significantly improve the collaboration across all teams and divisions.
- Completed the buildout and relocation of staff into the Bureau’s Southeast Regional office in Atlanta, Georgia, allowing the Bureau to collaborate more effectively with other partner financial regulators who also have their offices in the region.
- Implemented several changes to the procurement process to increase opportunities for women and minority owned businesses. These included: Conducting vendor outreach sessions geared toward the women and minority owned business community; inserting a good faith effort contract clause in all of its solicitations and awards to ensure vendors’ workforces are diverse; and, incorporating a new clause for all new solicitations and contract awards requiring vendors to make a good faith effort to promote and ensure inclusion of historically Black colleges and universities and minority institutions for subcontracts.
- Improved its decision-making and resource allocation processes by maturing our enterprise risk management (ERM) capabilities.