The Consumer Financial Protection Bureau (CFPB) has been using Civil Investigative Demands (CIDs) to investigate whether financial institutions are engaging in conduct that violates consumer financial laws. Two recent decisions of the CFPB in response to requests to modify or set aside these CIDs are instructive for others who may wish to challenge requests for information or documents. This article, published as an Emerging Issues Analysis by Lexis/Nexis (2013 Emerging Issues 6890) describes the CFPB's rules for CIDs, and analyzes the Bureau's first two orders in response to deny or set aside CIDs. The orders are useful in that they provide guidance on CFPB's standards for considering and responding to petitions to modify or set aside. The authors, AJ Dhaliwal and Amanda Raines of BuckleySandler, LLP, close with a handful of considerations that should inform decisions to challenge CIDs issued by CFPB.
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