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By: Mark Dobosz
January 21, 2016
Public-Private partnerships have often proven to be some of
the best examples of meeting the needs of a variety of infrastructures the US
economy and its consumers. An article by Andrew Deye in the June 2015 Kennedy
School Review indicates that “In a September 2014 report, Moody’s Investors
Service stated, ‘the United States has the potential to become the largest P3
market in the world, given the sheer size of its infrastructure’.”
The data centers of our regulatory agencies are a key
infrastructure to consumer information and deserve no less than one that can be
best built for the 21st century through a Public Private Partnership
(P3).
The bureau can be more effective in its
mission where trust exists between consumers and the agency that works to
protect them... The current process for maintaining the inventory of these data
sets is manually intensive. In an effort to improve transparency, the CFPB’s
Chief Data Office is transitioning from this manual process of tracking these
data sets to an automated tool…The CFPB’s chief data office is in the process
of transitioning the manual process to the use of an automated tool.
KPMG’s findings on the
CFPB’s privacy policies and procedures
The CFPB has been highly emphatic in requiring the financial
services and the debt collection industry to increase compliance by
establishing and maintaining systems and procedures to ensure consumer data
privacy in all transactions. All of
which have utilized “automated” systems that have proven to be effective and
efficient in the credit ecosystem. Millions have been spent by the industry to
meet these demands in the past 5-7 years. The National Creditors Bar
Association (NARCA) members report a 300%+ increase in compliance costs from
2011-2014.
The experience of implementing secure data automation of
consumer financial and personal information is an asset that is currently
underutilized by the CFPB. A Public Private Partnership (P3) between industry
and the regulatory agency would bring to market the exact types of automation
and systems that the regulatory agency has been requiring industry to implement
in their financial services and credit ecosystem operations in the past few
years. Why offer consumers two standards and systems of data privacy and
security protection when a standardized system that is recognized as best in
class could be built through a P3 and provide consumers with the confidence
that both government and the private sector are on the same page.
As Deye concludes in his article, at a conceptual level, the
primary drivers of infrastructure P3s—new sources of capital, cost savings,
risk transfer, and accountability—remain strong. Government officials at all
levels (federal, state, and local) continue to operate in an environment of
constrained financial resources and citizen expectations for efficient and
timely operations.”
If I-595, the Port of Baltimore and the Long Beach Courthouse (all recent successful P3 projects) can provide citizens with safe, secure and efficient infrastructure, then a CFPB-Financial Services P3 should be pursued to provide US consumers with the same level of benefits. This P3 could be a “coming of age” in the regulator’s history.
About the Author: Mark Dobosz currently serves as the Executive Director for NARCA – The National Creditors Bar Association. Mark is a one of NARCA’s speakers on many of the creditors rights issues impacting NARCA members.
The National Creditors Bar Association (NARCA) is a trade association dedicated to creditors rights attorneys. NARCA's values are: Professional, Ethical, Responsible
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