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CFPB Report: 2017-SR-C-015 September 20, 2017

The CFPB Generally Complies With Requirements for Issuing Civil Investigative Demands but Can Improve Certain Guidance and Centralize Recordkeeping

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When investigating consumer financial law violations, the CFPB may issue civil investigative demands, or CIDs, for information from entities subject to the investigation or from third parties that may have relevant information. We assessed whether the CFPB adheres to legal requirements and internal policies and procedures for issuing CIDs.

We found that the CFPB generally complies with the procedural elements of the Dodd-Frank Act and with its internal policies and procedures when issuing CIDs. However, the CFPB can improve its

  • guidance for crafting the statements and notifications of purpose associated with each CID
  • recordkeeping of the documentation associated with CIDs

Our report contains recommendations to reduce the agency's exposure to legal, operational, and reputational risk.