Such an uninformative catch-all phrase defeats any specificity provided by the reference to the FCRA. See ACICS, 854 F.3d at 691–92 (“The inclusion of the uninformative catch-all phrase ‘any other Federal consumer financial protection law’ does nothing to cure the CID’s defects.”) . . . Simply put, the CFPB does not have “unfettered authority to cast about for potential wrongdoing.” In re Sealed Case (Admin. Subpoena), 42 F.3d 1412, 1418 (D.C. Cir. 1994). As such, it must comply with statutory requirements, and here it did not.
In Consumer Financial Protection Bureau v. Source for Public Data, L.P., 2018 WL 4258966, at *3 (C.A.5 (Tex.), 2018), the Court of Appeals for the Fifth Circuit rejected the CFPB’s petition to enforce a CID against an alleged consumer reporting agency, where the only the wrongdoing the CFPB listed was “FCRA violation” and “any other federal consumer financial law.”.