Saved by the En Banc: CFPB Appears Here To Stay

K&L Gates LLP

The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has been an agency under fire.[1] Acting Director Mick Mulvaney has begun to institute significant changes at the Bureau.[2] And last year, a panel of the D.C. Circuit Court of Appeals held that the Bureau’s leadership structure – a single director who can be removed only for cause – violates the separation of powers requirement of Article II of the U.S. Constitution.[3] But in a long awaited en banc decision, the D.C. Circuit reversed that panel’s decision. Rather, in PHH Corp. v. Consumer Financial Protection Bureau,[4] the court held that the Bureau’s structure is consistent with separation of powers principles.[5] As discussed below, businesses subject to the CFPB’s supervisory and enforcement authority will need to continue to remain vigilant.

In January 2014, the CFPB initiated an enforcement proceeding against mortgage services provider PHH Corporation (“PHH”). The Bureau alleged that PHH’s captive reinsurance program violated certain kickback provisions under Section 8 of the Real Estate Settlement Procedures Act (“RESPA”). The Bureau ordered PHH to pay a $109 million disgorgement penalty for the infractions.[6] PHH appealed the decision to the D.C. Circuit, asserting, among other matters, that the CFPB’s structure, whereby the director is removable by the president only for cause, was unconstitutional.[7]

In particular, PHH challenged Section 5491(c)(3) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), which established that the CFPB director may only be removed “for inefficiency, neglect of duty, or malfeasance in office.”[8] In other words, the president may only remove the sole director of the CFPB “for cause” as to opposed to “at will.”[9] PHH argued that this structure violates Article II separation of powers requirements because it impairs the president’s ability to exercise supervision and direction over the CFPB.[10] Through its challenge, PHH hoped to convince the D.C. Circuit that the CFPB never had the constitutional power to impose the $109 million penalty.

In 2016, a panel of the D.C. Circuit adopted PHH’s argument.[11] Circuit Judge Kavanaugh, writing for the majority, reasoned that the for-cause removal provision, coupled with the sole-directorship structure of the CFPB, did not provide acceptable executive oversight and was inconsistent with fundamental principles of liberty.[12] The court vacated the CFPB’s decision in the underlying enforcement action and determined that the Dodd-Frank Act must be modified to provide for at-will removal of the CFPB director by the president.[13] The CFPB filed a petition for rehearing en banc.

The En Banc Decision
The D.C. Circuit, sitting en banc, heard further argument in May 2017. PHH and numerous amici supporters (including the U.S. Department of Justice, writing on behalf of the U.S. government [14]) maintained that the CFPB’s sole-directorship structure, with a for-cause removal limitation, violated Article II. On January 31, 2018, the D.C. Circuit disagreed with them.

In the En Banc Decision, the majority held that the Article II question has nothing to do with the fact that the CFPB has only one director. Rather, the panel determined that the question is resolved by focusing simply on the language of the for-cause removal provision in Section 5491(c)(3) of the Dodd Frank Act. Because that same language (“inefficiency, neglect of duty, or malfeasance”) has already been approved by the Supreme Court in the seminal Article II case, Humphrey’s Executor v. United States, the court held that the president “retained ample tools” to supervise and direct the CFPB.[15] The court also held that, because the CFPB’s role as a financial regulator is not a “core executive function[],” there is no threat to the president’s powers or to the U.S. Constitution.[16] In this instance, the majority singled-out financial regulators as a whole, stating that “[t]he CFPB fits comfortably within precedent and tradition supporting the independence of the financial regulators that safeguard the economy.”[17] If the En Banc Decision is ultimately upheld, this special treatment of financial regulators could allow for increased autonomy of financial regulators down the road.

Parting with the majority, the dissenting members of the en banc court panel agreed with PHH that the CFPB’s structure was inconsistent with Article II requirements, offering two approaches for resolution of the issue. Circuit Judge Kavanaugh reaffirmed his position in line with the D.C. Circuit’s 2016 decision and reiterated that the removal clause should be severed from the Dodd-Frank Act.[18] This approach would allow the president to remove the CFPB director at will but the CFPB would otherwise remain intact as it currently exists. Conversely, Circuit Judge Henderson took a more aggressive approach, determining that Title X of the Dodd-Frank Act (i.e., the entirety of the CFPB portion of the legislation) should be stricken and Congress should be responsible for reconstructing legislation to create a proper, constitutional agency.[19] Certainly, these arguments will be raised by PHH if the decision is appealed to the Supreme Court.[20]

What Comes Next for the CFPB?
It is unclear whether PHH will petition for certiorari to the U.S. Supreme Court for review of the En Banc Decision’s ruling that the CFPB’s structure is constitutional. If the case does not progress to the Supreme Court, it will be remanded to the CFPB for further proceedings. And under the En Banc Decision, “to hold PHH liable” under RESPA Section 8, “the CFPB must … show that the … [amount] paid [for reinsurance is] more than reasonable market value….”[21] Meanwhile, the Bureau is currently without a Senate-confirmed director. Richard Cordray resigned as Director in November 2017 and nominated CFPB Deputy Director Leandra English as his successor. President Trump, however, appointed Director of the Office of Management and Budget Mick Mulvaney to serve as the Acting Director of the CFPB, a role in which he currently serves. At least one attempt to block Mr. Mulvaney’s appointment has been dismissed by the U. S. District Court for the Southern District of New York,[22] while Ms. English has her own suit pending in a D.C. federal court seeking court endorsement of her position as the rightful successor to the directorship.[23]

Acting Director Mulvaney, for his part, has already started to restructure the CFPB’s operations from within. Mr. Mulvaney announced in a recent email to CFPB staff that he intends to bring the CFPB’s Office of Fair Lending and Equal Opportunity under his direct oversight. Mr. Mulvaney has also taken steps to alter CFPB rulemaking, such as the CFPB’s “Payday Rule,” aimed at effecting a major overhaul of the small dollar lender industry.[24] On the rule’s effective date, Mr. Mulvaney announced that the CFPB “intends to engage in a rulemaking process so that the Bureau may reconsider the Payday Rule.”[25]

For regulated industry members, uncertainty regarding the depth and breadth of the CFPB’s activities continues to be the name of the game. But because the CFPB is likely here to stay in some manner, interested stakeholders may want to engage with the CFPB and Congress to advocate for their particular policy objectives.

[1] See K&L Gates Alert, Down But Not Out: The CFPB’s Future May Be Uncertain, But Industry Participants Must Remain Vigilant.
[2] See, e.g., Mick Mulvaney, The CFPB Has Pushed Its Last Envelope, Wall Street Journal, Jan. 23, 2018,
[3] 839 F.3d 1 (D.C. Cir. 2016), vacated on other grounds by, No. 15-1177, 2018 WL 627055 (D.C. Cir. Jan. 31, 2018) (en banc).
[4] --- F.3d ----, 2018 WL 627055, No. 15-1177 (D.C. Cir. Jan. 31, 2018) (the “En Banc Decision”).
[5] The D.C. Circuit’s decision also breathed new life into the underlying three-judge panel’s decision regarding the proper interpretation of Section 8(c) the Real Estate Settlement Procedures Act (RESPA). For coverage of the effect of the D.C. Circuit’s decision as it pertains to RESPA, see K&L Gates Alert, Back from the Dead: The D.C. Circuit Breaths Life Into RESPA Section 8 Safe Harbor.
[6] Decision of the Director at 36-37, In re PHH Corp., No. 2014-CFPB-0002 (June 4, 2015),
[7] See Brief for PHH at 45-46, PHH Corp. v. CFPB, No. 15-1177 (D.C. Cir. Sept. 28, 2015).
[8] 12 U.S.C. § 5491(c)(3).
[9] Id.
[10] See Brief for PHH at 45-46, PHH Corp. v. CFPB, No. 15-1177 (D.C. Cir. Sept. 28, 2015). According to PHH, the CFPB’s structure would comport with Article II if: (1) the CFPB director were removable at will by the president; or (2) the CFPB were restructured as a bi-partisan, multi-member commission (along the lines of the Securities and Exchange Commission or the Federal Trade Commission). Id.
[11] 839 F.3d 1 at 36-39.
[12] Id. at 36.
[13] Id. at 39.
[14] See Brief for the United States as Amicus Curiae, PHH Corp. v. CFPB, No. 15-1177 (D.C. Cir. March 17, 2017).
[15] En Banc Decision, 2018 WL 627055, at *6. In Humphrey’s Executor, the Supreme Court determined that the power held by the commissioners of the FTC did not violate the Constitution’s separation of powers requirement even though the commissioners were not removable at will by the president. Humphrey's Executor v. U.S., 295 U.S. 602, 623-26 (1935) (concerning the president’s power to remove commissioners of the FTC).
[16] En Banc Decision, 2018 WL 627055, at *6.
[17] Id. at *16.
[18] Id. at *102 (Kavanaugh, J., dissenting).
[19] Id. at *67 (Henderson, J., dissenting).
[20] Circuit Judge Randolph wrote a third dissenting opinion addressing an alternative Article II question focused on the constitutional authority of the administrative law judge who wrote the initial decision of the CFPB. Id. at *102-04 (Randolph, J. dissenting). Circuit Judge Randolph concluded that the case should not be remanded to the CFPB until the Supreme Court decides Lucia v. SEC, a case that will presumably resolve that alternative Article II issue. Id. The Supreme Court granted certiorari in the Lucia case on January 12, 2018. Lucia v. SEC, No. 17-130, 2018 WL 386565 (S. Ct. Jan. 12, 2018). The Article II issue in Lucia, whether administrative law judges are inferior officers, or simply employees of their respective agencies, was not addressed in the En Banc Decision.
[21] En Banc Decision, 2018 WL 627055, at *6 (reinstating panel’s holding regarding interpretation of RESPA and instructions on remand to the CFPB); see PHH, 839 F.3d at 44 (“On remand, the CFPB may determine whether the relevant mortgage insurers in fact paid more than reasonable market value to the reinsurer … for the reinsurance.”).
[22] See Memorandum Opinion & Order, Lower East Side People’s Fed. Credit Union v. Trump, No. 17-09536 (S.D.N.Y. Feb. 2, 2018), ECF No. 54.
[23] See English v. Trump, No. 17-02534 (D.D.C.).
[24] See K&L Gates LLP Alert, Payday Loan Rule Finalized: “Ability to Repay” Requirements Narrowed, but Challenges and Risks Loom Large.
[25] See K&L Gates LLP Consumer Financial Services Blog, Payday Loan Rule Is Officially A Go - Or Is It? and Payday Loan Rule to Be Officially Reconsidered.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© K&L Gates LLP | Attorney Advertising

Written by:

K&L Gates LLP

K&L Gates LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.