Despite a perceived lull in enforcement actions, recent Biden administration Consumer Financial Protection Bureau (CFPB) investigations have utilized some "'novel and aggressive' legal theories," partner Allen Denson tells Law360.
Allen also reveals the agency's requests for executive officer compensation figures and other financial data are arriving earlier in the investigation process, potentially indicating an "emboldened" CFPB.
"What that's designed to do is send a message that they are looking to find the deep pockets and hold individuals accountable," Allen says. "Starting off an investigation with that kind of a request is a very different procedure than asking at the end when you're trying to negotiate a settlement."
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Originally published by Law360
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