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Civil Investigation Demand Consumer Financial Products Financial Services Industry

Orrick, Herrington & Sutcliffe LLP

Chopra testifies at House, Senate committee hearings

On June 12, the Senate Committee on Banking, Housing, and Urban Affairs held a hearing to address the CFPB’s Semi-Annual Report to Congress. The CFPB Director, Rohit Chopra, in his opening statement addressed the Committee to...more

Womble Bond Dickinson

Increasing Volume of Pro Se, Frequent Litigants, and Pre-Litigation Demands & Arbitration Claims in Financial Services Litigation...

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This is the first in a series of articles based on Womble Bond Dickinson’s recent 2024 Trends in Financial Services Litigation seminar. Managing consumer disputes and consumer lawsuits has always been a fact of life for...more

Epstein Becker & Green

Pending Supreme Court Decision on the Constitutionality of the Consumer Financial Protection Bureau’s Funding Structure Results in...

The United States Supreme Court’s pending decision in Consumer Financial Protection Bureau v. Community Financial Services Association of America Ltd., et al. (“Community Financial Services Association of America Ltd.”) in...more

Akerman LLP

Explainer Things: Episode 10

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Our newsletter’s title is a nod to the semi-scary Netflix series Stranger Things. No surprise we are VERY excited about Halloween. You may notice that our regular pop culture references have gone horror-themed for this...more

Orrick, Herrington & Sutcliffe LLP

When the CFPB Investigates: Responding to a CFPB CID

Since opening its doors in July 2011, the Consumer Financial Protection Bureau (CFPB) has not been shy about initiating enforcement actions against companies and individuals subject to its authority, recovering billions of...more

Orrick, Herrington & Sutcliffe LLP

CFPB denies small-dollar lender’s request to set aside CID

The CFPB recently denied a lender’s request to set aside or modify a civil investigative demand (CID) issued in January related to its short-term and small-dollar lending practices. The lender’s redacted petition asserted...more

Orrick - On the Chain

CFPB Makes an Entrance: Crypto Products Targeted

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Ending doubts regarding its interest in the space, the Consumer Financial Protection Bureau (CFPB) has for the first time publicly acknowledged its investigation of a crypto company — and it’s likely a sign of things to come....more

Manatt, Phelps & Phillips, LLP

Student Lending: CFPB Investigates Point-of-Sale Financing

A leading online payments system platform that offers point-of-sale (POS) financing reports it received a Civil Investigative Demand (CID) from the Consumer Financial Protection Bureau (CFPB) for allowing educational...more

ArentFox Schiff

A Common Thread in 2019 CFPB Enforcement Activity: Denials of Petitions to Set Aside CIDs

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As promised, we return now to provide an overview of the CFPB’s petition activity for the year to-date. In addition to the Bank of America (BofA) petition denial we discussed last month, the CFPB has issued a series of...more

Ballard Spahr LLP

Kraninger sets tone for vigorous enforcement agenda in decisions on five petitions to modify or set aside CFPB CIDs

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Consumer advocates have heavily criticized Director Kraninger and former Acting Director Mick Mulvaney for taking a much less aggressive attitude towards enforcement than former Director Cordray. ...more

Ballard Spahr LLP

FTC Cites Need For Improvement In Compliance Reports

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Less than a week after warning subpoena and CID recipients to take their obligation to respond “seriously,” the FTC took aim at perceived inadequacies in compliance reports submitted pursuant to FTC consent orders and...more

Ballard Spahr LLP

CFPB Files First Lawsuit Under Acting Director Mulvaney

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The CFPB filed its first new lawsuit under acting Director Mulvaney yesterday, alleging that a pension advance company and its president made predatory loans to consumers that were falsely marketed as asset purchases.  ...more

Ballard Spahr LLP

CFPB refuses to set aside or modify CID

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The CFPB, in a decision and order signed by Acting Director Mulvaney, has denied the petition filed by Firstsource Advantage, LLC (Firstsource) to modify or set aside a civil investigative demand (CID) (Petition) that was...more

Ballard Spahr LLP

Democratic state AGs comment on CFPB CID process

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A group of 16 Democratic state attorneys general have sent a letter to the CFPB in response to its Request for Information Regarding Bureau Civil Investigative Demands and Associated Processes. ...more

Ballard Spahr LLP

CFPB seeks comment on its guidance and implementation support

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The CFPB has issued a request for information that seeks comment on its guidance and implementation support. Comments on the RFI must be received on or before 90 days after the date the RFI is published in the Federal...more

Bradley Arant Boult Cummings LLP

Speak Up! The CFPB Wants Your Feedback

January 17th, the Consumer Financial Protection Bureau (CFPB) announced that it is seeking “evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers.” The CFPB is expected to...more

Ballard Spahr LLP

The Eastern District of Michigan Affirms the CFPB's Broad Authority to Issue Civil Investigative Demands

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A recent decision from the Eastern District of Michigan in CFPB v. Harbour Portfolio Advisors, LLC; National Asset Advisors, LLC; and National Asset Mortgage, LLC serves as a reminder that the Consumer Financial Protection...more

Ballard Spahr LLP

CFPB/NY AG lawsuit against RD Legal Funding may signal greater scrutiny of non-loan financial products such as merchant cash...

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The CFPB and the New York Attorney General this week filed an action against RD Legal Funding, LLC, two of its affiliates, and their principal (collectively, “RD”), alleging that a litigation settlement advance product...more

Ballard Spahr LLP

Ninth Circuit affirms tribal lenders subject to CFPB investigative demands

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The Ninth Circuit recently issued its opinion in CFPB v. Great Plains Lending, LLC, et al., in which three tribal-affiliated, for-profit lending companies (“Tribal Lenders”) challenged the authority of the CFPB to issue civil...more

Ballard Spahr LLP

Tribal Sovereign Immunity Not a Bar to Payday Lending Enforcement Action, California Supreme Court Rules

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In a state enforcement action alleging violations of California's lending law and seeking to enjoin continued lending to state residents, the California Supreme Court has ruled that the two tribally affiliated entities that...more

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