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The DC Circuit’s Big CFPB Ruling Carries Wide Implications. Here’s What’s Next

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Second, last Friday the CFPB filed a petition for en banc rehearing of the PHH decision, citing serious concerns about the DC Circuit’s "dramatic and unprecedented ruling." 2 The petition requests review of the holdings that found (1) the CFPB’s single-director structure to be unconstitutional, and (2) that the bureau misinterpreted RESPA.

Today the United States Court of Appeals for the DC Circuit issued its long-awaited ruling in the PHH v. CFPB appeal (opinion here). LLW has written about the PHH case here and here before, and below are some quick takeaways from the court’s 110-page ruling for industry watchers: The court deter.

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In a concise panel ruling (CFPB vs. Accrediting Council for Independent Colleges and Schools) that no doubt stings for the Consumer Financial Protection Bureau (CFPB), the US Court of Appeals for the DC Circuit has held that the CFPB failed to provide adequate notice of the purpose of a civil investigative demand (CID) it issued to an.

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