Several Bureau of Consumer Financial Protection (CFPB) civil investigative demand (CID) processes have room for improvement, CUNA wrote to the bureau Thursday. The bureau’s request for information on the CID process is the first in the series of RFIs the bureau issues to assess how it is performing its basic functions.
The bureau investigates potential violations by issuing CIDs and compelling testimony at investigative hearings. A CID permits the Bureau to demand production of documents, written responses and oral testimony, among other things.
“CUNA recognizes that aggressive use of CIDs may be necessary to investigate activities of profit-driven financial institutions and individuals that are engaging in fraud or other serious violations,” the letter reads. “However, credit unions genuinely wish to meet or exceed regulatory requirements designed to protect consumers and will cooperate with reasonable bureau inquiries. Current bureau CID processes do not have policies or procedures that protect legitimate financial institutions, such as credit unions, from unwarranted government intrusion.”
CUNA also noted: