News & Analysis as of

Civil Investigation Demand Financial Services Industry Banking Sector

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 - Finance 20/20

CFPB Changes Policy Regarding Civil Investigative Demands

On April 23, the Consumer Financial Protection Bureau (CFPB) announced changes to its current policies regarding Civil Investigative Demands (CIDs). ...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

CFPB “Can Improve” Recordkeeping and Notifications of Purpose in Civil Investigative Demands, OIG Finds

Ballard Spahr LLP on

On September 20, 2017, the Federal Reserve’s Office of Inspector General (“OIG”) issued a report on the CFPB’s process for issuing Civil Investigative Demands (“CID”). The OIG found that the CFPB “generally complied” with...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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...

Ballard Spahr LLP on

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

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