CFPB Adopts AFSA CID Changes
Today, 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. We are pleased that the Bureau has adopted an approach that is consistent with the association's recommendations.
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.
AFSA will continue to keep members updated via AFSA Alerts and the AFSA Blog.
April 23rd, 2019 by Dan Bucherer