FOIA Advisor

Court opinion issued Dec. 14, 2017

Court Opinions (2017)Allan BlutsteinComment

Frank LLP v. CFPB (D.D.C.) -- determining that: (1) Bureau properly invoked Exemption 7(E) to withhold certain records concerning enforcement action against debt collector; (2) Bureau properly withheld attorney interview notes prepared during active investigation into potential target pursuant to Exemption 5 (attorney work-product); (3) plaintiff failed to exhaust administrative remedies with respect to second request for failure to pay fees; (4) Bureau has improper practice of treating records submitted in response to Civil Investigative Demands ("CIDs") as "voluntarily" submitted for  purposes of Exemption 4; (5) Bureau properly treats entities that buy and collect on debts as "financial institutions" for purposes of Exemption 8. 

Summaries of all opinions issued since April 2015 available here.