Any company, particularly if conducting business is a highly regulated industry, risks being served with a subpoena or a civil investigative demand (collectively, “CID”) from a governmental agency or entity. As set forth...more
In December, the CFPB denied a petition by a debt collection agency to set aside a civil investigative demand (CID) issued last October. The company challenged the Bureau’s authority to issue the CID on the grounds that the...more
Washington State’s Attorney General settled a case against sandwich franchisor, Jersey Mike’s, over antipoaching provisions in its franchise agreements. Since 2018, Washington State has made agreements with more than 60...more
Back in April, we reviewed several new initiatives within the Federal Trade Commission (FTC) focused on eliminating “wasteful, legacy regulations and processes that have outlived their usefulness,” including “process reforms”...more
As any company that has received a civil investigative demand (CID) from the Consumer Financial Protection Bureau (CFPB) knows, the Bureau’s authority to issue CIDs is a powerful tool that leaves recipients with limited...more
BELTWAY - Every Last Penny Counts - Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more
Holland & Knight and the Word of Mouth Marketing Association (WOMMA) hosted a half-day forum that featured government officials discussing hot-button issues in consumer protection regulation and enforcement. Speakers at the...more
On August 3, 2015, the United States District Court for the Southern District of New York issued an opinion and order in Kane v. Healthfirst, Inc., et al.[1] that provides the first judicial interpretation of the requirement...more
The Southern District of New York has spoken on one of the first issues to confront those seeking compliance with the new “60-day rule” under the Affordable Care Act (ACA), and it does not bode well for defendant hospitals...more
Consumer Financial Protection Bureau (CFPB) Director Richard Cordray rejected challenges to the CFPB's investigation powers and the Bureau's use of broadly worded civil investigative demands (CIDs). Director Cordray did so in...more
The CFPB has denied the petition of a lead generation company and its employee to modify or set aside a civil investigative demand (CID). As we reported, among the petitioners’ arguments for why the CID should be set aside...more