News & Analysis as of

Civil Investigative Demand Civil Investigation Demand

Recent Investigation Closing Suggests FTC’s Process Reforms Might Be Meaningful

by BakerHostetler on

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

Companies Challenge CFPB’s Authority to Issue Civil Investigative Demands

by McGuireWoods LLP on

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

Financial Services Report, Summer 2016

by Morrison & Foerster LLP on

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

Key Takeaways from the Consumer Protection Forum

by Holland & Knight LLP on

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

The 60 Day Rule — Identification and Knowing Avoidance

by Ballard Spahr LLP on

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

Kane and the “60-Day Rule”: The Unforgiving World of Medicare and Medicaid Overpayments

by BakerHostetler on

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

CFPB Affirms Its Authority to Serve Civil Investigative Demands - Companies That Transact Business with Financial Institutions...

by Holland & Knight LLP on

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

CFPB denies lead generation company’s petition to modify or set aside CID

by Ballard Spahr LLP on

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

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