Name change would cost millions

The name change proposed at the Consumer Financial Protection Bureau could cost regulated entities $300 million if the agency goes through with its switch to the Bureau of Consumer Financial Protection moniker.

The name change proposed at the Consumer Financial Protection Bureau could cost regulated entities $300 million if the agency goes through with its switch to the Bureau of Consumer Financial Protection moniker.

Acting Director Mick Mulvaney began roll-out of the new name earlier this year with a new logo in March and updated language in press releases in April. Signage in the agency’s lobby was rearranged in June.

An internal CFPB analysis of the name change, obtained by The Hill, projected additional costs for banks, mortgage providers, payday lenders and credit card companies.

The agency’s analysis found that financial services companies would have to underwrite the move to the tune of $300 million. The name change would necessitate updates to internal databases, regulatory filings and disclosure forms in order to comply with rules. An agency analysis estimated that the changes necessary to comply with the Fair Credit Reporting Act, the Electronic Fund Transfer Act and certain mortgage regulations would cost firms $100 million for each rule. The CFPB cited a 2010 cost-benefit analysis of agency name-changes in its internal report.

A name change would cost the agency between $9 million and $19 million for updates to internal materials and its website, The Hill reported.

The BCFP formulation is how the agency is referred to in Title X of the Dodd-Frank Act, which created the agency in 2010. Mulvaney pointed out this fact in his April 11 appearance before the House Committee on Financial Services. “The organization is the Bureau of Consumer Financial Protection,” he said. “The Consumer Financial Protection Bureau does not exist…The CFPB technically does not exist.” Dodd-Frank uses both the CFPB and BCFP formulations to refer to the agency, however.

At the time, critics argued that the move essentially threw away years of media exposure and brand recognition, as well as reordering the bureau’s focus and priorities.

The agency is aiming to update its website to reflect the name change by March, The Hill reported. But it could take several months or years to implement the rebranding in federal regulations charged to the agency.

Fredrikson & Byron Law