Share
The Bureau of Consumer Financial Protection (CFPB) has issued a series of Requests for Information (RFIs) on various practices in order to assess the efficiency and effectiveness of the Bureau. NAR recently submitted comments on the first in the series focused on Consumer Investigative Demands (CIDs) and associated processes used by the Bureau to gather facts during an investigation to pursue potential violations of Federal consumer financial laws.
In the comment letter, NAR explained the extensive demands placed on a CID recipient and the difficulty in communicating with Bureau staff who may be unfamiliar with the business practices at issue or the underlying financial laws that prompted the investigation. CID recipients reported devoting substantial time and resources to complying and protecting against a broad CID, including covering costly legal teams to manage the entire process. As a result, NAR advocated for CID processes to be narrowly tailored and in line the Bureau’s authority and objectives to improve recipients’ understanding and responses. Improved Bureau communication and necessary flexibility to address covered entities’ concerns would also facilitate a more fruitful process for all parties involved.
NAR will be submitting comments on a number of other RFIs and encourage feedback from members wishing to weigh in on these important issues anonymously. For more on the CFPB’s RFI efforts, including future requests, please visit this page on the CFPB website.