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Is the CFPB bound by its non-binding guidance?

USA - March 8 2018 Predictability and certainty are crucial components of the consumer finance market. Consumers crave it, as do industry participants. A common...

Steven vonBerg, Brandy A. Hood.

D.C. Circuit Panel Rejects CFPB’s RESPA Interpretation and Alters its Structure in PHH Corp. v. CFPB

USA - October 12 2016 On October 11, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion vacating a $109 million...

Jon David D. Langlois, Jeffrey P. Naimon, John P. Kromer, Joseph M. Kolar, Jeremiah S. Buckley.

Special Alert: Department of Defense Issues Interpretive Rule Regarding Compliance with the Military Lending Act

USA - August 26 2016 Today, the Department of Defense ("DoD" or "Department") published in the Federal Register an interpretive rule regarding compliance with its July...

Manley Williams, Andrew W. Grant, Sasha Leonhardt, Valerie L. Hletko.

Special Alert: CFPB Finalizes Amendments to Mortgage Servicing Rules

USA - August 9 2016 On Thursday, the CFPB issued its long-awaited final amendments to the mortgage servicing provisions of Regulations X and Z. The Bureau had sought...

Benjamin B. Klubes, Jon David D. Langlois, Melissa Klimkiewicz, Jeffrey P. Naimon, John P. Kromer.

Special Alert: CFPB Proposes Amendments to Know Before You OweTRID Rule

USA - August 3 2016 On Friday, the CFPB issued its much anticipated proposal to amend the KBYOTRID rule. The CFPB crowded dozens of proposed changes into the almost 300...

Jeffrey P. Naimon, Clinton R. Rockwell, John P. Kromer, Joseph M. Kolar, Jeremiah S. Buckley.