Removing Barriers Blog

CFPB Announces Changes to CID Policy
Posted April 23, 2019 by CUNA Advocacy

The CFPB issued a release announcing changes its policies related to Civil Investigative Demands (CIDs). The amended policy is designed to ensure more information is provided by the CFPB at the onset about the potentially wrongful conduct under investigation. 

The updated policy for CIDs “will provide more information about the potentially applicable provisions of law that may have been violated.” In addition, CIDs will also specify the business activities subject to the Bureau’s authority. 

According to the Bureau, the new policy “takes into account recent court decisions about notifications of purpose, and is consistent with a 2017 report by the Bureau’s Office of Inspector General that emphasized the importance of updating Office of Enforcement policies to reflect such developments.”  The Bureau also incorporated feedback received in response to its 2018 Request for Information (RFI) on CIDs, which was issued as part of Acting Director Mulvaney’s call for evidence on the Bureau’s policies and procedures. 

CUNA submitted a letter in response to the 2018 RFI which called on the Bureau to increase transparency and avoid unwarranted government intrusion.