April 23, 2019
CFPB Changes Policy Regarding Civil Investigative Demands
Today, the Consumer Financial Protection Bureau announced that it changed its policy regarding Civil Investigative Demands to ensure they provide more information about potential violations of law under investigation.
Under the revised policy, "CIDs will provide more information about the potentially applicable provisions of law that may have been violated. CIDs will also typically specify the business activities subject to the Bureau's authority. In investigations where determining the extent of the Bureau's authority over the relevant activity is one of the significant purposes of the investigation, staff may specifically include that issue in the CID in the interests of further transparency." The revised policy takes into account recent court decisions concerning the "notification of purpose" section of CIDs, as well as comments the Bureau received in response to Requests for Information issued in 2018 seeking feedback about, among other things, its use of CIDs in enforcement investigations.
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