In February 2014, Morrison & Foerster published the client alert "The CFPB Targets Mortgage Reinsurance Yet Again."
Summary:
The Consumer Financial Protection Bureau filed an administrative enforcement action against PHH Corporation, alleging a nearly 15-year "mortgage insurance kickback scheme" by its mortgage origination and reinsurance subsidiaries involving "hundreds of millions of dollars" in allegedly improper reinsurance fees. This action follows on the heels of the Bureau's consent orders totaling $15.5 million with five mortgage insurers, settling allegations that the insurers' agreements with mortgage originators violated the Real Estate Settlement Procedures Act (RESPA). How this new action might relate to those settlements remains to be seen. But statements by PHH indicate that this could be one of the first contested CFPB administrative actions.
Click here to read the full alert.
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.
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