CFPB Civil Penalties and How to Mitigate Them
CFPB Theories of Recovery and Mitigating Factors The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) continues to aggressively serve Civil Investigative Demands (“CIDs”) upon lead generators operating within verticals that implicate federal consumer financial laws. What follows is intended to briefly address multiple theories of recovery that the CFPB could potentially
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