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Sixth Circuit in Carter Refuses to Defer to HUD’s RESPA Guidelines

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

CFPB Continues to Finalize Elements of “Points and Fees” Test as Implementation Date Draws Closer

The CFPB’s final ability-to-repay rule (Rule), issued January 10, 2013, implements Dodd-Frank mortgage reforms requiring creditors to make good faith determination that a consumer has reasonable ability to repay his or her...more

Negotiating the Enforcement Maze: A CFPB Civil Investigative Demand

The Consumer Financial Protection Bureau (CFPB or Bureau), through its Office of Enforcement, may conduct inquiries of institutions or persons to investigate compliance with the federal consumer financial laws for which it is...more

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