On October 7, the Consumer Financial Protection Bureau (CFPB) took steps to clarify its interpretation of how settlement service providers may comply with the “no kickback” and “unearned fee” provisions of Section 8 of the...more
Some very important and potentially game-changing legislation was recently passed. On Oct. 24, 2018, Congress enacted the Eliminating Kickbacks in Recovery Act of 2018 (or EKRA) – a statute that potentially eliminates legal...more
Following a now familiar approach, the CFPB issued a bulletin today that suggests deep disapproval of an entirely legal practice. This time, its target is marketing servicing agreements (MSAs), which are agreements that...more