TENURE AT CFPB

2.5+ years
SUSAN the ATTORNEY OCCUPATION

Attorney-Advisor
INFORMATION-DRIVEN DILIGENT ORGANIZED LOCATION

“
Washington, D.C.
I want the full picture before providing advice and

”
SUSAN’S CORE TRAITS
support.
Goals
BIO
Susan works within the Legal division of CFPB, where she focuses primarily on agency-related administrative law. She serves as in-house • Complete projects in a timely manner, ensure
counsel providing legal advice and support to employees and leadership on matters related to CFPB funding, procurement, intellectual legal sufficiency in all documentation
property and other issues that require legal understanding. Susan prefers to get work done independently with access to all necessary • Ensure consistency with CFPB messaging and
documentation so she can cross-reference information and get the whole picture. language

TO SUSAN, THE INTRANET SHOULD BE Collaboration

Easily searchable with rich information on the internal processes of the divisions she supports. Given she is driven by information, clean and up-to-
• Works closely with program offices and
date documentation on processes that may need legal support, such as procurement, is a must.
Procurement on legal standing and compliance
with federal regulations
CORE DIMENSIONS OF SUSAN’S INTRANET USAGE • Advises program offices on general
administrative law
Usage: Frustrations:

Once a week, usually to find background on a program office's As a CFPB employee:

Environment
processes in place. ⁃ Too many disparate pages and links to systems in different places
⁃ Search results are cumbersome and requires her to click through almost all HEADQUARTERS
She will always search the wiki before reaching out to
someone she knows in the program office. results to know if something is worthwhile Drives individual tasks and
spends the majority of her time
As an Attorney: reading and responding to
Information Accessed: ⁃ Broad search results often force her to look through dozens of results to requests and inquires.
find exactly what she is looking for
⁃ Processes and procedures TELEWORKING
⁃ Finding information for procedures and documents that span multiple
⁃ POCs in area of interest Uses time away from the
divisions is time-consuming and difficult
⁃ Policy documentation office to get work done that
⁃ She does not have a clear sense of what information is on the wiki or how
⁃ Administrative materials and links to systems requires uninterrupted
to find it
⁃ Employee profiles concentration. Plans ahead
by printing out necessary
documents.
 TENURE AT CFPB

1.5+ years
BILL the ATTORNEY OCCUPATION

Enforcement Attorney
ANALYTICAL THOROUGH DETAIL-ORIENTED LOCATION

“
Washington, D.C.

”
I use the Intranet as a starting point to get the BILL’S CORE TRAITS
information I need from across the CFPB.
Goals
BIO • Manage cases effectively
Bill is an Enforcement Attorney within the SEFL division of CFPB, where he spends his time providing legal counsel on cases related to • Ensure he is following the legal precedent and is
examinations. On each case, Bill spends a significant amount of time getting up to speed on the subject area of a case and tracking down consistent with previous rulings, reports and
individuals that have experience in the space. At each step Bill is often wary of “re-inventing the wheel,” knowing that his fellow attorneys have cases
likely seen certain motions and judgements before. He will often ask his supervisor or fellow attorneys who he can connect with for this key
information.

TO BILL, THE INTRANET SHOULD BE Collaboration

A place that he can find out what the CFPB has done or said regarding legal matters in the past. Furthermore, he would like access to the • Works closely with a core team of attorneys
supporting research and reporting provided by groups like RMR in the event he gets moved to a case with a product he is not familiar with. from SEFL, Legal and RMR on each case
• Shares information with other Enforcement
CORE DIMENSIONS OF BILL’S INTRANET USAGE Attorneys

Usage: Frustrations:
Environment
Once a week, usually to find a POC to get more information for As a CFPB employee:
a case he is working on ⁃ He finds it difficult to understand how the organization is structured and HEADQUARTERS
who is doing what throughout the CFPB Drives individual tasks but brings
Occasionally he uses the wiki to conduct research and find
⁃ Inconsistent usage of tags makes it difficult to get what he needs in team members and experts
internal reports, white papers and memos. He also references
for advice and information as
consumerfinance.gov to find public-facing documentation.
As an Attorney: needed.
⁃ No single document management tool with final versions of documents
Information Accessed: TELEWORKING
⁃ Walks around the office trying to find information on previous cases by
Plans ahead for teleworking
⁃ POCs in area of interest talking to fellow attorneys and supervisors in person days by printing out
⁃ Research, reports, white papers, memos, CFPB necessary documents and
announcements cutting down on meetings.
⁃ Policy documentation, though he looks at external
policy very often as well
 Journey Applies To
Experience Map Intranet and Information Usage for Attorneys
The below user journey map outlines a standardized journey that Attorneys take when accessing the intranet
and other information resources inside and outside the CFPB to carry out a variety of legal tasks.
Bill Susan
Enforcement Attorney
Attorney Advisor
PHASES

Detect and Search Locate and Act

Trigger Navigation Result

NOTE: Printing and saving are often interrelated by

Use my Own Materials frequency. If the information retrieved appears to be a Print Document for Review
Locate Internal Material one-off, it will be printed but not saved.
I’ll look for previously In my office and computer I I like to have a hard copy I can
? utilized CFPB information have kept information I If an item appears to be a piece of information that carry with me for teleworking or
Need for Counsel may come up again and again, the attorney will often
Regs/Rules Research thought may be needed later in-office purposes
CFPB employees look to so I’m guided by precedent save the copy locally and then print for review.
Knowledge of published
me for legal ground on a
law or regulation needs to
variety of issues Save the Result to my Stash
be cross-checked
ACTIVITIES

I save it to my H Drive, where I

keep items that I may need to
Track down POC
reference back to
I’ll try the directory if I know
who I’m looking for; if not I’ll
ask peers or use the wiki
Keep my POC in Mind
Case Information
Mentally note who helped me
My current case requires more Use External Legal Source and how they did so I can
in-depth knowledge about the I may need to reference come back for more help
CFPB's preferred handling external legal sources from
outside bureaus

As a federal agency, compliance with the law and partner regulations continues to be of paramount importance to the CFPB The navigation process for Attorneys is a varied and complicated one. Given that law requires research, referencing and cross-checking, most Attorneys felt comfortable The Attorney’s result is straightforward. If they do not simply reference the material and move on, they take three common
across a multitude of functions. Attorneys must understand the law as it applies to the markets that are regulated by CFPB as with combing through numerous sources of material to put together everything they need. This search is a fundamental part of their day-to-day activities. paths.
DESCRIPTION

well as the law as it appli es to the agency itself, requiring a great deal of expertise and research.
More than anything, Attorneys are concerned about precedent in how the CFPB has handled certain events before and if this
information is documented. Whether this involves rule-making, litigation, counsel or elsewhere, previous information and
understanding is what drives an Attorney’s information workload.
To do this, Attorneys would often try a mixture of internal, external and peer resources to find the information they needed, and this is dependent on the subject matter. If they have been helped by a key POC, they will commit the person and their office to memory, often returning if they face
For Attorneys working on litigation or enforcement, they want to know what cases have been decided in a certain realm before and show any public communications the similar issues down the road. If they have not already done so, they will save the material to their personal stash for
CFPB has put out on these matters before. For internal guidance, the Attorney will often reference internal policy and broader federal policy. Different mixtures of this reference later (memos, previous legal decisions, internal reports, white papers, etc.). Many Attorneys expressed their
blend of external and internal resources pervade much of the information gathering process. desire to have paper copies to annotate and read in their office, on their commute and particularly at home.

To gain this information, the Attorney will often look internally to resources generated by the CFPB or externally to regulation Sources of information are varied, but often Attorneys will either use their own personal files that they have saved to their hard drive or track down a point of contact that While many Attorneys expressed a lack of desire for working at home, if this ever was the case they made sure to bring
that has been documented elsewhere in the federal government. may have more information to supplement their search. longer documents home to review.

“I support program offices in “When I begin a case, I’ll use “If someone has been helpful in the “I typically save case memos that “Home is great in the sense that it is
MOTIVATIONS

making sure documentation is
legally sufficient for their
contracts.”
“If another part of the CFPB has
questions about our rules, we help
them to understand, serving as
the SMEs.”
FRUSTRATIONS
resources to try to find out what the
CFPB has done in this area, then I
will try to find people in the division
who have done this before.”
“If you have 3 similar cases in the
past and you are the 4th, you
should know about those other 3.”
Common Themes:
In many cases of counsel, policy or
regulatory items the Attorney will
utilize external legal sites to find
information. They never articulated
relying on others to access this
information; this searching is just
part of being an Attorney.
“I want to find information around
what the CFPB has done in the past,
especially anything around decisions
on how we would interpret or apply
the law.”
“…look for press releases, director
notes, any content around that
subject.”
“My habit is to jump into the human
link and identify someone who has a
broad understanding of what is going
on at the CFPB that can point me in
the right direction.”
“I use the wiki to identify a POC to
contact, sometimes from a content
page or an office listing.”
“I have a repository of case memos,
reports and other subject matter to
reference.”
Common Themes:
past, I will call them the next time I are emailed around in case I need
Many Attorneys indicated different
have a similar issue.” them in the future.”
external tools and websites they
access for information
“Sometimes we get emails from the
CFPB that are about ‘don’t forget to
do these 3 things when you conduct
an investigation’ … I usually save
those emails.”
quiet. I plan out my telework days by
printing documents I need to review.”
“A good day is when I am able to print
documents and have all the relevant
pieces near me so I can cross-
reference and feel like I have the whole
picture.”

“[In ethics] we are not the world’s
most popular people. Most
employees see us as an obstacle
and sometimes get angry when they
are told they cannot do something.”
COMMON CASES
Common Themes:
Many Attorneys indicated not
feeling connected with and
informed of the work going on
throughout the CFPB, in particular
having ready access to what has
been done before.
Common Themes:
Tracking down the right information
from across the CFPB can be
daunting and time-consuming, and
Attorneys acknowledged always
feeling like they might be missing
something.
“I am better at finding things externally
than I am internally. I usually have to
go through the 49 search results on
the wiki to find what I am looking for
and I don’t always find it.”
“If you can’t feel confident in how up
to date information is on the wiki, you
won’t check it.”
“Sometimes I just go to the list of “I usually save documents, policies
“I have started to collect my own and important emails to my H drive,
people in an office and start calling
[files about products] and materials but I always worry about having the
everyone on the list to find the right
for different subject matters to most up-to-date information.”
person.”
reference, mostly to protect myself if not applicable not applicable not applicable
I get assigned to something that I am
“It can take a lot of time to learn who
not very knowledgeable of.”
to talk to. I always worry there is
more out there I am not getting.”

• Procurement requires final legal
checks at multiple stages in the
process
• Ethics Attorneys must ensure
CFPB employees comply with
certain aspects of the law
• At the onset of a case, Attorneys
will ask others around them if
they have done similar work in
the past or know of anyone who
has
• Attorneys had books of
government regulations or
references to websites that they
used
• Often time finding information is
just a matter of time
• Cross-referencing CFPB
regulation, internal policy and
external legal items was usual
• Attorneys indicated frustration
around the lack of a document
management tool that is
searchable with final versions of
documents, memos, reports and
cases
• If the Attorney knows the direct
name of the person they need, he
or she will use the director to
simply look up contact info
• If the attorney does not have a
direct contact, he or she will use
the wiki to find POCs in the office
to contact
• If a section leader or other CFPB
employee sends out information
that may be useful later, Attorneys
will save it to their hard drive and
reference it later
• Many Attorneys mentioned
looking at the federal registrar’s
website and even the external
ConsumerFinance.gov for citing
regulation
• For internal matters, the GAO’s
regulations were also referenced
• Many Attorneys indicated having
POCs in different areas of the
CFPB that they know to call for
certain inquires
• If during this process, an Attorney
locates something that may be of
use down the road, he or she will
save the material to their hard
drive
• Many times the Attorney will save
something if they think they may
be put on a case or a matter
relating to certain items later
• Most Attorneys prefer to come in
to the office to complete their
work, but indicated that home was
a nice alternative when they were
getting up to speed on a case or
had documents to review and
mark up