The U.S. Court of Appeals for the District of Columbia Circuit reached three important conclusions in its Oct. 11 decision in the PHH Corp. versus the Consumer Financial Protection Bureau case: the CFPB Director will henceforth work at the pleasure of the president, a traditional understanding of the Real Estate Settlement Procedures Act regarding the permissibility of captive reinsurance agreements was affirmed, and the traditional three-year statute of limitations remain in place regarding agency enforcement of RESPA’s Section 8. In my view, that is a triple win for the banking industry.
Two years . . .
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