BCFP councils now limited to 6 members each, new recently posted charters show

Three advisory panels established under the 2010 financial reform law that also created the Bureau of Consumer Financial Protection (BCFP, formerly known as CFPB) have been pared down in membership slots to six each, according to new charters for the panels that were signed and dated June 5 by Acting Director John (“Mick”) Mulvaney but posted only recently on the bureau’s website.

The old membership lists for the panels – the Consumer Advisory Board (CAB), Community Bank Advisory Council (CBAC) and Credit Union Advisory Council (CUAC) – are still posted on the site, and so is the June 6 blog post that announced the panels were being “reconstituted.”

In that post, the bureau said the consumer protection bureau was continuing the above three panels and that it “will use the current 2018 application and selection process to reconstitute the current advisory groups with new, smaller memberships. By both right-sizing its advisory councils and ramping up outreach to external groups, the Bureau will enhance its ability to hear from consumer, civil rights, and industry groups on a more regular basis.”

Previously, there were 25 members listed for CAB, 19 for CBAC and 17 for CUAC. The June 6 blog post did not specify how many members would be included in the future, and no new announcement – at least, no new blog post or press release – has been posted on the website since.

The statutory authority behind these panels, which provide consumer and industry input to the bureau director, is found in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Dodd-Frank required the establishment of the Consumer Advisory Board (CAB) and describes as “discretionary” the creation of the Community Bank Advisory Council (CBAC) and Credit Union Advisory Council (CUAC).

CAB is required by the law to have at least six members who are recommended by the regional Federal Reserve Bank presidents on a rotating basis. These are the only members provided for under the advisory board’s new charter. The board, also as provided under law, will meet at least twice a year, the charter states.

The CBAC and CUAC will also have six members, each with one-year terms, according to the new charters, and each council will meet at least once a year. Only community bank and credit union employees will be included, respectively, on the CBAC and CUAC, the charters show.

While the charters are dated June 5, there are handwritten notes in the “filing date” sections indicating the charters were amended June 20 and filed with the bureau director (Mulvaney), the Senate Banking Committee, House Financial Services Committee, the Committee Management Secretariat of the General Services Administration (GSA) and provided to the Library of Congress.

Consumer Advisory Board charter

Community Bank Advisory Council charter

Credit Union Advisory Council charter

June blog post on panel changes to come

March notice soliciting nominations