Bureau Adopts AFSA Suggestions to Improve Vague Investigative Process

This week, the Consumer Financial Protection Bureau (CFPB) announced changes to its policy regarding Civil Investigation Demands (CIDs). The changes are intended to provide more information to the subject of the CID. AFSA has long advocated that the Bureau’s CIDs be more specific. Last April, in response to one of the Bureau’s several requests for information, AFSA submitted comments emphasizing that CIDs should be reasonable. AFSA’s efforts has resulted in the Bureau adopting an approach that is consistent with the association’s recommendations.“The American Financial Services Association (AFSA) has long advocated that the Bureau’s Civil Investigation Demands (CIDs) be both reasonable and more specific given the impact they have on member companies who received vague CIDs in the past,” the association said in a note to members and a statement to the news media. “We are pleased that the Bureau is taking this approach that is consistent with recommendations we submitted responding to the Bureau’s requests for information.”

From the CFPB press release:

“Consistent with the updated 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.”

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