Radian Group Inc. Notes to Consolidated Financial Statements - (Continued) With respect to the  Samp  case and the other similar putative class actions discussed above, Radian Guaranty believes that  the claims are without merit and intends to vigorously defend itself against these claims.  We are not able to estimate the  reasonably possible loss or range of loss for these matters because the proceedings are in a very preliminary stage and there is  uncertainty as to the likelihood of a class being certified or the ultimate size of a class. In addition to the litigation discussed above, we are involved in litigation that has arisen in the normal course of our  business. We are contesting the allegations in each such pending action and management believes, based on current knowledge  and after consultation with counsel, that the outcome of such litigation will not have a material adverse ef fect on our  consolidated financial condition. However , the outcome of litigation and other legal and regulatory matters is inherently  uncertain, and it is possible that one or more of the matters currently pending or threatened could have an unanticipated ef fect  on our liquidity, financial condition or results of operations for any particular period. In addition to the private lawsuits discussed above, we and other mortgage insurers have been subject to inquiries from  the Minnesota Department of Commerce and the Of fice of the Inspector General of HUD, requesting information relating to  captive reinsurance. The Dodd-Frank Act amended RESPA and transferred the authority to implement and enforce RESP A from  HUD to the Consumer Financial Protection Bureau (“CFPB”). In January 2012, we and other mortgage insurers received a  request for information and documents from the CFPB relating to captive reinsurance arrangements, and in June 2012, we and  other mortgage insurers received a Civil Investigative Demand (“CID”) from the CFPB as part of its investigation to determine  whether mortgage lenders and private mortgage insurance providers engaged in acts or practices in violation of the Dodd-Frank  Act, RESPA and the Consumer Financial Protection Act. On December 7, 2012, we filed a petition with the CFPB to set aside  or modify the CID, which has not yet been ruled upon by the CFPB.  We are cooperating with the CFPB in its investigation and  are in active discussions with the CFPB with respect to our response to the CID, including various alternatives for resolving  this investigation. Various regulators, including the CFPB, state insurance commissioners or state attorneys general may bring  actions or proceedings regarding our compliance with RESP A or other laws applicable to our mortgage insurance business.  We  cannot predict whether additional actions or proceedings will be brought against us or the outcome of any such actions or  proceedings.  We are also currently contesting proposed adjustments resulting from the examination by the IRS of our 2000 through  2007 tax years. The IRS opposes the recognition of certain tax losses and deductions that were generated through our  investment in a portfolio of non-economic REMIC residual interests currently held by CMAC of  Texas. We appealed the  proposed adjustments to Appeals and reached a tentative settlement agreement with  Appeals. Upon subsequent review and  consideration, however, Appeals informed us that it was no longer willing to settle on the originally proposed terms.  After  several attempts to reach a compromised settlement, we were notified in January 2013 that  Appeals rejected our latest offer and  plans to issue a formal notice of deficiency within three to six months. Upon receipt of the notice, we will have ninety days to  pay the assessed tax liabilities, penalties and interest or petition the U.S.  Tax Court to litigate the matter. Litigation of the  deficiency amount may result in substantial legal expenses and the litigation process could take several years to resolve.  We can  provide no assurance regarding the outcome of any such litigation. See Note 16 for additional information.  Under our master insurance policy, any suit or action arising from any right of the insured under the policy must be  commenced within two years after such right first arose for primary insurance and within  three years for certain other policies,  including certain pool insurance policies. We continue to face a number of challenges from certain lender customers regarding  our insurance rescissions and claim denials, which have resulted in some reversals of our decisions regarding rescissions or  denials. We are currently in discussions with customers regarding rescissions and claim denials, which if not resolved, could  result in arbitration or additional judicial proceedings.  The assumptions embedded in our estimated default to claim rate on our  in-force default inventory includes an adjustment to our estimated rescission and denial rate, to account for the fact that we  expect a certain number of policies for which an initial intent to rescind letter has been sent to our lender customers to remain  in-force and ultimately to be paid, as a result of valid challenges by such policy holders during the limited period specified in  such letters. See Note 10 for further information.  261