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ABA: The American Bankers Association
Compliance News

Bureau Announces Change Regarding CIDs

A year ago this week, ABA submitted its first of 13 comment letters to the CFPB Requests for Information (RFI), which then Acting Director Mulvaney initiated to generate feedback on CFPB policies, procedures and practices. The first RFI requested feedback on the use of Civil Investigative Demands (CID) in enforcement. ABA's comment letter pointed out that while CIDs can be important investigatory tools if carefully used, they can be—and too often were—employed abusively in ways that violate reasonable due process. We urged the CFPB to provide CID recipients more information about the underlying purpose of the CID and the products and services under investigation. This week the CFPB announced it is amending the CID policy to ensure "CIDs will provide more information about the potentially applicable provisions of law that may have been violated. CIDs will also typically specify the business activities subject to the Bureau’s authority."