The CFPB needs to improve the way it informs recipients of its civil investigative demands (CIDs) of the purpose of its investigations, according to a recent report from the bureau’s Office of Inspector General.At issue are the CFPB’s internal guidelines for crafting notifications of purpose associated with CIDs. The guidance calls for broad statements of purpose, to allow for flexibility, the OIG noted. However, “The guidance does not expressly remind enforcement attorneys of the need for statements of purpose to be compliant with relevant case law on notifications of purpose, including any developments in such case law, or remind them to revisit the statement of purpose in a revised opening memorandum if the purposes of the investigation evolve.” The ...