Following Borders & Borders PLC’s (Borders) successful summary judgment motion last summer, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a motion for reconsideration with the federal district court in...more
On October 8, 2015, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a Compliance Bulletin on RESPA Compliance and Marketing Services Agreements (“MSAs”)(“Compliance Bulletin”). The Compliance Bulletin’s...more
10/20/2015
/ Affiliated-Business Arrangements ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Enforcement Actions ,
Kickbacks ,
Marketing ,
Marketing Services Agreements ,
Quid Pro Quo ,
Referral Fees ,
RESPA ,
Safe Harbors
In a decision two years in the making, on Wednesday, November 27, 2013, the Sixth Circuit Court of Appeals brought some clarity to the use of affiliated business arrangements (“ABAs”) under Real Estate Settlement Procedures...more