OLA Files Comment in Response to Evidentiary RFI Dealing with Improving the CID Process
At the end of 2017, Acting Director Mulvaney of the Consumer Financial Protection Bureau (CFPB) announced that he would be undertaking a new initiative to ensure that the Bureau’s operations were fulfilling its proper and appropriate functions to best protect consumers. In response to these “calls for evidence,” OLA formed a task force and last week filed its first comment letter regarding Civil Investigative Demands (CIDs). The comments outlined a full list of issues including costs, time commitments of responding to a CID and deficiencies in the ability to challenge CID’s. To date, the CFPB has issued 12 “Evidentiary RFI’s” focusing on Enforcement, Supervision, Rulemaking, Market Monitoring, Education.
Notice of Proposed Rulemaking on Personal Financial Data Rights Docket No. CFPB-2023-0052; RIN 3170-AA78