Civil Investigative Demand Reform Act of 2025
The Civil Investigative Demand Reform Act of 2025 would overhaul how the Consumer Financial Protection Bureau (CFPB) uses civil investigative demands (CIDs) in its enforcement process. The bill tightens and clarifies several procedural aspects: it extends the time window to issue CIDs to up to six years after a violation, requires CID contents to reference specific facts, creates an “attorney question and response” mechanism to clarify the scope of a CID, strengthens confidentiality around petitions, expands the set-aside grounds for challenging a CID, and provides for judicial review if a petition to modify or set aside a CID is denied. Taken together, these changes emphasize due process protections for respondents and introduce more procedural checks on CFPB investigations, potentially slowing or shaping enforcement actions.
Key Points
- 1Extended time window for CIDs: A CID must be served no later than six years after the date of the alleged violation, expanding the period CFPB can pursue investigative demands from enforcement actions.
- 2CID specificity requirement: CIDs must reference particular facts, increasing clarity about exactly what is being investigated.
- 3Attorney-question and response process: An attorney advising a person subject to a CID can submit questions about the demand’s scope; the Bureau must respond within the shorter of 20 days after questions are submitted or the period from service to the return date, with potential extensions for return dates and petition deadlines.
- 4Confidential treatment of petitions: The contents of petitions to modify or set aside a CID, and the petition materials, become part of the confidential material protected under the CID framework.
- 5Expanded grounds to set aside: The bill creates specific bases to challenge a CID, including if the demand is unduly burdensome or duplicative or can be obtained from a more convenient or cheaper source, and it clarifies constitutional or other legal rights as defenses.
- 6Judicial review for denied petitions: If the Bureau denies a petition to modify or set aside a CID, that denial would be subject to judicial review in court.