According to TheRegister.com, the Consumer Financial Protection Bureau’s cybersecurity program has been deemed “not effective” in a recent audit by the Office of the Inspector General. The agency’s cybersecurity maturity dropped from level-4 (“managed and measurable”) to level-2 (“defined”) since the previous assessment. Auditors found 35 systems operating either with expired authorizations or without ever undergoing proper authorization processes. The CFPB continues using outdated software that no longer receives security updates, including one package reaching end of life in 2024. Contractor support for security functions plummeted from 66% to 25% after task orders were terminated, compounded by government staff departures. The agency largely agreed with the findings but disputed the characterization of its security posture as “lax.”
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What actually went wrong here
Look, cybersecurity maturity dropping two full levels isn’t just a minor slip – that’s basically your entire security program collapsing. The CFPB went from having measurable, managed security controls down to just having them defined on paper. And here’s the thing that really worries me: 35 systems running without proper authorization? That’s not just paperwork – that’s potentially leaving sensitive consumer financial data exposed.
The RAM situation is particularly concerning. Risk Acceptance Memorandums are supposed to be part of a larger authorization package, not the whole enchilada. Using RAMs alone is like saying “we know this is risky but we’re doing it anyway” without actually documenting what those risks are or how you’re managing them. For an agency handling personal financial information and confidential supervisory data, that’s downright scary.
The staff exodus crisis
So why did this happen? The audit points directly to the staffing bloodbath. Contractor support dropping from 66% to 25% in months is catastrophic for any security program. And it’s not just contractors – government staff have been leaving too. When you lose the people doing continuous monitoring and security testing, your entire security posture becomes theoretical rather than operational.
The timing here is no coincidence either. These cuts align perfectly with the Trump administration’s efforts to gut the CFPB, including plans to cut about 90% of its workforce. But here’s what I don’t get – if you’re going to cut staff, shouldn’t you at least maintain the critical security functions? Apparently not.
Broader implications
This isn’t just a CFPB problem – it’s a pattern we’re seeing across federal agencies. Similar cuts have hit CISA and other critical infrastructure agencies. We’re basically watching the systematic dismantling of America’s cybersecurity capabilities while threat actors are becoming more sophisticated.
Think about it: an agency responsible for protecting consumers’ financial data can’t even maintain basic system authorizations or stop using outdated software. What does that say about our overall national security posture? And if this is happening at the CFPB, where else is it happening that we haven’t discovered yet?
The CFPB says it’s working to redeploy staff from other offices, but that’s like moving deck chairs on the Titanic. You can’t just plug non-security people into security roles and expect things to improve. Cybersecurity requires specialized skills and experience that you can’t acquire through on-the-job training during a crisis.
