These days, there is certainly no shortage of investigators, auditors, regulators, and prosecutors inundating the financial services industry with audits, inquiries, civil investigative demands, and subpoenas. Some of these inquiries, such as audits by an entity’s regulator, are familiar territory, and companies know the drill in responding to them. What companies find more unnerving is the unfamiliar, such as Civil Investigative Demands from the Consumer Financial Protection Bureau (CFPB) or subpoenas from the New York State Department of Financial Services (DFS). These entities didn’t even exist five years ago, and companies and their counsel are only now beginning to understand the expectations of these relatively new players in the enforcement space.
One such late arrival to this already crowded field is the Office of Inspector General (OIG) of the Federal Housing Finance Agency (FHFA). Like the CFPB and the DFS, the FHFA didn’t exist five years ago; the FHFA came into existence in 2008 with the enactment of the Housing and Economic Recovery Act (HERA). And the Inspector General of the FHFA arrived on the scene even later: the agency’s first Inspector General, former federal prosecutor Steve Linick, wasn’t nominated and confirmed until 2010.
Originally Published in BNA's Banking Report - December 24, 2013.
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