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Abstract: 

In this article, the authors provide a detailed description of the steps in the CFPB’s investigation process from the triggers for an investigation to settlement strategies with the agency. The steps include the CFPB’s required Meet and Confer for the lawyers, its civil investigative demand process, the NORA procedures, and the agency’s options in resolving an open investigation. The authors discuss these steps from the perspective of the company being investigated, and the agency’s expectations and common practices. A companion second article, in the February 2021 issue, will describe the investigation process in the New York State Department of Financial Services.

Keywords: Consumer Financial Protection Bureau; CFPB Examinations; CFPB Enforcement Investigations; Notice and Opportunity to Respond and Advise (NORA)

Affiliations:  1: Goodwin Procter, LLP; 2: Guidepost Solutions LLC; 3: Goodwin Procter, LLP.