RFIs generate 3,000-plus letters so far; ‘Civil Investigative Demands’ accounts for 3 in every 4

More than 3,000 comment letters have been submitted on the dozen “requests for information” issued by the federal consumer financial protection agency since January – but more than three out of every four letters address the very first request addressing “civil investigative demands” (CIDs).

Bureau of Consumer Financial Protection (BCFP, formerly known as the CFPB) Acting Director Mick Mulvaney began issuing the RFIs in January in a “call for evidence” from the public about how (or whether) the agency was doing its job. Following that, the agency issued the dozen RFIs; all were eventually issued with 90-day comment periods.

Since then, two comment periods have closed on the first and second RFIs issued. The first RFI, on “civil investigative demands” (CIDs) issued by the bureau, generated 2,401 comment letters by the time the comment period closed April 26. (According to the American Bar Association, a CID is a subpoena-like tool often used by consumer protection offices that tends to be expansive, typically seeking specified documents.)

The second RFI, on “Rules of Practice for Adjudication Proceedings” (which closed for comments May 7) generated (by contrast to the first) 33 comment letters.

So far, the RFI on CIDs has generated, by far, the most comment letters – about 78% – of the total 3,092 filed (as of Wednesday, according to regulations.gov). The top four total comments following that are 398 on “Enforcement Processes” (comments close May 14); 110 on “Consumer Complaint and Consumer Inquiry Handling Processes” (July 16); 36 on “Public Reporting Practices of Consumer Complaint Information” (June 4); and “Rules of Practice for Adjudication Proceedings” (which closed this week).

At the bottom of the list (so far) are the eight comment letters generated by the RFI on “Guidance and Implementation Support.”