Civil Investigative Demand Reform Act of 2025
HB1653, the Civil Investigative Demand Reform Act of 2025, would amend the Consumer Financial Protection Act to change how the Bureau of Consumer Financial Protection (CFPB) issues and enforces civil investigative demands (CIDs). The bill adds a six-year outer limit for issuing a CID based on the date of the alleged violation, requires the demand to identify the conduct at issue with specific reference to particular facts, and creates a formal process for attorneys to ask the Bureau questions about the scope or breadth of a demand. The Bureau would have to respond within 20 days or by the CID return date, whichever is shorter, and could extend the return date and petition deadline when questions are submitted.
The bill also expands confidentiality protections to cover petitions submitted to the Bureau, and it broadens the grounds on which a recipient may seek to modify or set aside a CID. Under the bill, a demand could be challenged for noncompliance with statutory requirements, violation of constitutional or other legal rights or privileges, or if it is unduly burdensome, disproportionately expensive, outside the scope of the inquiry, unreasonably cumulative or duplicative, or obtainable from a more convenient, less burdensome, or less expensive source. If the Bureau denies a petition to modify or set aside a demand, that denial would be subject to judicial review.
If enacted, the bill would amend sections of the Consumer Financial Protection Act of 2010 governing CIDs, limiting the CFPB’s investigative timing and increasing procedural protections for CID recipients. It would impose new specificity, response, confidentiality, and review requirements that could make CFPB investigations slower and more contestable, while giving businesses and their counsel additional tools to challenge or narrow demands. The bill would directly affect the CFPB, regulated financial entities, and attorneys responding to agency investigations.
Based on the bill text and available context, the measure appears to be framed as a procedural reform rather than a substantive rollback of consumer protection law. The introduction by bipartisan sponsors suggests at least some cross-party interest in tightening CID procedures and improving fairness for recipients. No committee debate or vote history is available, so there is no recorded floor or committee sentiment beyond the bill’s reform-oriented framing.
The main points of contention are likely to be the balance between CFPB investigative authority and protections for CID recipients. Supporters would likely favor the six-year limit, greater specificity, attorney question-and-answer process, expanded confidentiality, and judicial review as safeguards against overbroad or burdensome demands. Opponents may argue these changes could impede enforcement, delay investigations, and make it harder for the CFPB to obtain information quickly in consumer finance cases. The most disputed provisions are likely the new time limit, the broader set-aside grounds, and mandatory judicial review of denied petitions.