Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
What would your company do if it received a broad civil investigative demand (CID) from the CFPB demanding the production within 30 days of thousands of pages of documents regarding operations, services, products, and...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
The Consumer Financial Protection Bureau (“CFPB”) was created to enforce the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”) and various consumer finance laws (e.g., Equal Credit Opportunity...more
The Consumer Protection Principles continue the CFPB’s expansive approach. Stating that it wants to ensure that “any new payment systems are secure, transparent, accessible, and affordable to consumers” and have “robust...more
For many public companies, the first issue they have to confront after they receive a government subpoena or Civil Investigative Demand (“CID”) is whether to disclose publicly that they are under investigation. Curiously, the...more
Dodd-Frank gives the Consumer Financial Protection Bureau (CFPB) the power to enforce and implement federal consumer financial protection laws, including home mortgage and other consumer credit regulations, plus powerful...more
On September 26, the CFPB issued a 10-page order denying a petition filed jointly by three tribal payday lenders that asked the CFPB to set aside the civil investigative demands (CIDs) the lenders received from the CFPB. The...more
The Consumer Financial Protection Bureau’s civil investigative demand (“CID”) authority has recently presented significant compliance difficulties for companies that have received requests for information relating to an...more
The U.S. government continues to ramp up investigations and enforcement actions against banks, mortgage companies and other financial services companies, including using tools such as the False Claims Act and its power to...more