UNITED STATES OF AMERICA Before the CONSUMER …...2015-CFPB-0029 Document 187 Filed 12/05/2016 Page...

UNITED STATES OF AMERICA Before the

CONSUMER FINANCIAL PROTECTION BUREAU

ADMINISTRATIVE PROCEEDING File No. 2015-CFPB-0029 __________________________

In the Matter of: ) )

INTEGRITY ADVANCE, LLC and ) JAMES R. CARNES, ) )

) Respondents. ) )

_________________________ )

DECLARATION OF ALUSHEYI J. WHEELER

District of Columbia:

1. I am counsel for the Consumer Financial Protection Bureau (Bureau) in the

above-captioned matter.

2. I was one of the attorneys working on the Bureau’s investigation into Integrity

Advance and James Carnes during 2013.

3. On January 7, 2013, the Bureau sent a civil investigative demand (CID) to

Integrity Advance. That CID included document requests and interrogatories. See

Attachment A.

4. The January 7, 2013 CID was the Bureau’s first CID directed to Integrity

Advance.

DECLARATION OF ALUSHEYI J. WHEELER

2015-CFPB-0029 Document 187 Filed 12/05/2016 Page 1 of 43

5. Integrity Advance made an initial partial production in response to the CID on

October 25, 2013.

6. Integrity Advance largely completed its production in response to the CID during

December of 2013.

7. Enforcement Counsel first obtained copies of Integrity Advance’s loan agreement

through the company’s productions in response to the January 7, 2013 CID.

8. Enforcement Counsel conducted a Notice and Opportunity to Respond and

Advise (NORA) call with Respondents’ counsel on October 23, 2014.

9. Respondents provided a NORA response to Enforcement Counsel on November

13, 2014.

10. Attached hereto as Attachment A is a true and accurate copy of the January 7,

2013 CID.

I declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the foregoing is true

and correct.

Executed on December 5, 2016 /s/Alusheyi J. Wheeler_____ Alusheyi J. Wheeler

Attachment A

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