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Legal Update

Court Rejects CFPB’s RESPA Interpretation, Declares Single-Director Structure Unconstitutional

18 October 2016
Mayer Brown Legal Update
On October 11, 2016, a three-judge panel of the United States Court of Appeals for the District of Columbia Circuit issued a ruling overturning a $109 million monetary penalty imposed by the Consumer Financial Protection Bureau (“CFPB” or “Bureau”). The decision in PHH Corporation v. CFPB addressed the unconstitutionality of the Bureau’s structure and the retroactive application of a new Real Estate Settlement Procedures Act (“RESPA”) interpretation and imposed RESPA’s three-year statute of limitations on the Bureau. This Legal Update discusses the ruling.


  • Andrew J. Pincus
    T +1 202 263 3220
  • Phillip L. Schulman
    T +1 202 263 3021
  • Holly Spencer Bunting
    T +1 202 263 3380
  • Ori Lev
    T +1 202 263 3270
  • Emily J. Booth-Dornfeld
    T +1 202 263 3296
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