On January 31, 2018, the US Court of Appeals for the District of Columbia issued its long-awaited en banc decision in PHH v. CFPB. The court reversed the three-judge panel holding that the structure of the Consumer Financial Protection Bureau (CFPB) is unconstitutional but reinstated the panel’s decision that the CFPB’s interpretations of the Real Estate Settlement Procedures Act (RESPA) are unlawful and may not stand and that the CFPB is subject to a three-year statute of limitations even when bringing RESPA claims administratively.
Please join Mayer Brown lawyers Andy Pincus and Phil Schulman as they discuss:
- The constitutional implications of the court’s ruling and whether PHH might appeal
- Whether the RESPA ruling will renew interest in marketing an advertising arrangement among settlement service providers
- What the court’s decision means for the CFPB’s “regulation by enforcement” activities
For additional information, please contact GFMI@mayerbrown.com.
Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.
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