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Thursday February 20, 2020

CPSC Staff Gave Five Reasons for Compliance Reorganization That Pulled in Some GC Lawyers

CPSC staff gave commissioners five reasons to support recently approved integration of some General Counsel staff into the Office Compliance and Field Operations. Robert Kaye remains director of the four-unit office with Jennifer Sultan as deputy.


There is one difference in the offices' names from a proposal that floated around late last year. "Resource Management" originally was to be called "Resource Management and Fast Track."


The units and their leaders are:

  • Enforcement and Litigation: Mary Murphy will oversee this work with Howard Tarnoff as deputy. He also will serve in one of two supervisory attorney slots. The other will be Leah Ippollito on an acting basis.

  • Regulatory Enforcement: The boss is Jennifer Timian with Carolyn Manley and Shaun Keller as next-tier supervisors.

  • Field Operations: Director Beverly Kohen has two deputies: Justin McDonough and Keven Barton.

  • Resource Management: Blake Rose will be in charge with Phil Bermel under him.

Verbatim, the five reasons used to support the changes were:

  • "Integration of the compliance enforcement function within one organizational unit in the agency is designed to facilitate strong case development by allowing for case management from case inception to resolution."

  • "The functions of the Compliance Division of the Office of General Counsel (OGC) were transferred to the Office of Compliance (EXC) to consolidate the enforcement function within one division as a way to maximize resources and effectiveness. Under this model, EXC is responsible for all elements of a case, from its entry point at the Commission through case development and resolution, either through voluntary agreement or administrative litigation. In addition, EXC, rather than OGC, is now responsible for pursing civil penalties for Commission approval of compromise agreements."

  • "This new structure strengthens the enforcement posture of the agency by eliminating competing, and sometimes conflicting, lines of authority; streamlining resources; developing consistent policy and strategic positions at the earliest stages of case development; and allowing seamless movement of a case from start to conclusion."

  • "The Division of Enforcement and Litigation within EXC is comprised of both Compliance Officers and attorneys who report to Mary Murphy, who was formerly the Assistant General Counsel for Compliance. She has supervisory authority to direct all legal and investigative work performed by the Office of Compliance. She reports through Jen Sultan, the Deputy Director of Compliance, to Rob Kaye, the agency’s Compliance Director."

  • "The agency’s Strategic Plan sets forth a number of goals to achieve its core consumer protection mission. Those goals include cultivating the most effective workforce, focusing on preventing hazardous products from entering the marketplace, and responding quickly to identified hazards. Consolidation of the agency’s enforcement function accomplishes those goals by putting in place a framework to develop the most effective workforce, a framework that would invigorate the enforcement function and thereby help achieve the Strategic Plan objectives."