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Factoring Company’s Identity Revealed: Future Income Payments Is the ‘John Doe’ Company Fighting the Consumer Financial Protection Board

A company that has been fighting the Consumer Financial Protection Bureau’s jurisdiction and authority to issue a civil investigative demand – and did so under the name “John Doe Company” because it said its business would be harmed if its identity were known – has now been revealed.

The company is Future Income Payments, LLC.

And the CFPB issued its civil investigative demand to look into whether the company violated any federal law in connection with transactions involving pensions, annuities, settlement proceeds, or other future-income streams of payments.

As described here, and here, in a 2-1 opinion (Doe Co. v. Cordray, No. 17-5206 (D.C. Cir. Mar. 3, 2017)), the U.S. Court of Appeals for the District of Columbia rejected Future Income Payments’ constitutional challenge to the CFPB’s authority, at least in the context of the company’s direct challenge to the CFPB’s civil investigative demand (CID).

The company identified itself in the papers it filed as a Philippines-based business that “purchases income streams from individuals who are entitled to receive periodic payments from a pension or similar source and who wish to sell a portion of the income stream derived from those payments.”

The federal appeals court concluded that Future Income Payments essentially sought a preliminary injunction against the CFPB without first exhausting its administrative appeals.  The appeals court also rejected the company’s arguments that its identity should remain a secret.

Thus, the company’s identity has now been unveiled in court-filed papers.  A Los Angeles Times article (headlined “‘Pension advance’ company is unmasked – and it’s no friend of California consumers”, available here) described the company as having previously been based in California, before officials in that state began investigating the company for potential violations of the law.


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