On Tuesday, October 11, 2016, the U.S. Court of Appeals for the District of Columbia Circuit issued the court’s highly anticipated decision addressing the Consumer Financial Protection Bureau’s (CFPB)’s enforcement action against the mortgage lender PHH Corporation (PHH). The case before the court raised a number of novel questions regarding the single-director structure of the CFPB, the CFPB’s authority with regard to prior agency interpretations, the status of informal interpretations issued by agencies, the CFPB’s statute of limitations for bringing administrative and enforcement actions and longstanding questions involving the interpretation of “safe harbor” provisions within section 8 of the Real Estate Settlement Procedures Act (RESPA).