Legal Issues

Browse articles from all of our Newsletters related to Legal Issues.

May 20, 2016 - Inside FHA/VA Lending

Around the Industry

HUD Sends Final Condominium Rule to OMB for Clearance. The Department of Housing and Urban Development has sent a final rule to the Office of Management and Budget that would make it easier for borrowers to obtain FHA financing for certified condominium units. Once issued, the final rule will replace temporary guidance which HUD issued in November last year to ease FHA’s condo approval process. The move is aimed at increasing affordable housing options for first-time and low-income homebuyers. The final rule is expected to reflect measures in the interim guidance, including modification of the requirements for condo project recertification, revised calculation of FHA’s required ownership-occupancy percentage, and expansion of eligible condo-project insurance coverages. IG Scrutinizes HUD Oversight of SFHAs’ Downpayment Assistance Programs. Residential lenders that rely on ...


May 20, 2016 - Inside FHA/VA Lending

VA Clarifies Guidance for Conveying Titled Properties to VA Secretary

The Department of Veterans Affairs has clarified the type of documents lenders would need to provide clear and marketable title for conveyed properties to the VA in all states and U.S. territories. Under VA rules, each conveyance or transfer of real property to the VA shall be acceptable if “the holder covenants or warrants against the acts of the holder and those claiming under the holder (e.g. by special warranty deed).” In addition, the conveyance would be acceptable if it entitles the VA Secretary to such title as is or if it is acceptable to prudent lenders, informed buyers, title companies and attorneys, generally in the community in which the property is located. The VA said its determination of clear and marketable title depends on state statutory requirements. As a general requirement, documents for proper conveyance of clear and marketable title to the VA include the ...


May 20, 2016 - Inside FHA/VA Lending

VA Issues New Servicing Guidance, Reminders on Foreclosures, Others

The Department of Veterans Affairs has issued new guidance and some servicing reminders in connection with mobile-home foreclosures, consent judgments, servicer transfers, liquidation appraisal fees and others. VA servicers must specifically refer to the mobile home in foreclosure declaration documents to ensure that both the home and the land are properly foreclosed, the VA said. Many states require two separate foreclosure procedures for every transaction – one to foreclose the interest on the land and the other to foreclose on the title of the mobile home. The VA said foreclosure on the title of the mobile home may have to be filed with state’s Department of Motor Vehicles (DMV). When a VA loan on a home on wheels is referred to foreclosure, the servicer must inform the foreclosing attorney that it is a mobile home and whether a DMV filing is required. The VA will reconvey the mobile home to the ...


May 20, 2016 - Inside FHA/VA Lending

Trade Groups Urge Congress to Reevaluate Appraisal Oversight

Trade groups representing lenders, homebuilders and appraisers have asked Congress to hold a hearing this year on the future of appraisal regulation. In a joint letter, five industry groups urged the Senate Committee on Banking, Housing and Urban Affairs to reevaluate oversight of the appraisal industry and the current federal regulatory structure for real estate appraisal. The committee last held an appraisal oversight hearing in 2004. Federal appraisal regulations have been untouched since the enactment of the Federal Financial Institutions Reform, Recovery and Enforcement Act of 1989, the trade groups noted. In addition, the groups asked that both federal and state responsibilities be reassessed to see if they continue to serve consumers and market participants well, as well as promote competition in the marketplace. In addition to federal regulation, states regulate appraisers as well. The groups want to know from Congress whether federal oversight of appraisers is still necessary.


May 20, 2016 - Inside FHA/VA Lending

Key Lessons for FHA Lenders from M&T Bank, Guild FCA Lawsuits

There are important details in the recent M&T Bank settlement with the Department of Justice and in this week’s announced filing of a lawsuit against Guild Mortgage that could help lenders avoid a potential false claims lawsuit, according to industry observers. The government’s complaints against the two FHA lenders were brought under the False Claims Act, which penalizes acts that intend to defraud the government and taxpayers. The government has been using this powerful statutory tool in the mortgage arena in its attempt to recover FHA losses arising from fraud and noncompliance with agency requirements. As in previous FCA cases against FHA lenders, both M&T Bank and Guild Mortgage were accused of false certification, lax underwriting, poor quality control, failure to review early payment defaults, and failure to self-report deficient loans and remediate problems in a timely manner. In addition, the ...


May 20, 2016 - Inside FHA/VA Lending

Attorneys See Potential Defense In Recent Circuit Court Rulings

Recent circuit court rulings may bolster FHA lenders’ defense against the government’s heavy use of the False Claims Act in FHA lending cases, according to industry attorneys. In the years following the financial crisis, the Department of Justice and the relators bar have used the FCA aggressively to target banks and nonbank mortgage lenders for losses incurred by FHA due to poor underwriting and false certifications. The DOJ and the Department of Housing and Urban Development have recovered billions of dollars through settlements with various mortgage lenders and servicers, using increasingly creative theories of liability to hold them responsible for FHA losses. This week, the DOJ filed a lawsuit in federal court in Washington, DC, accusing Guild Mortgage of improper origination and underwriting of FHA-insured mortgage loans from January 2006 through December 2011. As in ...


May 20, 2016 - Inside FHA/VA Lending

Deconsolidation Opened Credit Access, New Things to Think About

The rapid deconsolidation in the Ginnie Mae issuer community and shift to nonbanks helped expand access for borrowers, but it’s also given the agency new issues to consider, officials said. Back in 2010-11, three Ginnie issuers dominated the program, noted Ginnie Mae President Ted Tozer during the Mortgage Bankers Association secondary-market conference in New York this week. But those three firms now account for just 14 percent of the agency’s business, and nonbanks held a combined 70 percent of the market, he said. Many new firms became issuers in part so they could get away from the credit overlays imposed by the national aggregators, Tozer said. The result is that the average score on a Ginnie loan is now 60 points lower than on loans securitized by Fannie Mae and Freddie Mac, he added. Michael Drayne, senior vice president in Ginnie’s office of issuer & portfolio management, said the ...


May 20, 2016 - Inside MBS & ABS

Payout from $8.5 Billion BofA Settlement Cleared, UBS Seeks MBS Suit Dismissal, Court Favors Trustee

After nearly five years of legal entanglements, investors will soon receive their share of the $8.5 billion Bank of America agreed to pay in June 2011 to resolve legacy mortgage-repurchase and servicing claims associated with Countrywide Financial Corp. The payouts were delayed by legal wrangling over whether trustee Bank of New York Mellon had the authority to settle. Last year, the New York Supreme Court ruled in the trustee’s favor, and a state court judge recently approved the severance order and partial final judgment, which cleared the way for BNYM to begin distributing the settlement proceeds from 512 of the 530 trusts in the case. Twenty-two investors that suffered significant losses for their failed investment in MBS sold by Countrywide prior to the collapse of the housing market are...


May 16, 2016 - Inside the CFPB

Also in Brief: Capitol Hill Roundup

Hensarling Slams CFPB, Vows Big Changes to Dodd-Frank, the Bureau. During a speech last week at the National Center for Policy Analysis, Rep. Jeb Hensarling, R-TX, chairman of the House Financial Services Committee, pledged to push a package of pro-growth, pro-consumer reforms as an alternative to the Dodd-Frank Act, including clipping the wings of the CFPB. “At almost every opportunity, the bureau abuses and exceeds its statutory authority, which is already immense,” said the congressman. “The bureau operates with such secrecy, unaccountability, and bureaucratic tyranny it would make a Soviet Commissar blush.” As the committee moves forward with its plans for financial reform, Hensarling promised the Republicans will have ...


May 16, 2016 - Inside the CFPB

CFPB Looks to Ban Class Action Waivers in Arbitration Agreements

Earlier this month, the CFPB finally issued its long-awaited proposed rule to drastically scale back the ability of consumer financial companies to use pre-dispute arbitration clauses in their contracts for consumer financial products and services. The proposed rule would impose two sets of limitations on the use of pre-dispute arbitration agreements by covered providers of consumer financial products and services. First, it would prohibit providers from using such an agreement to block consumer class actions in court and would require providers to insert language into their arbitration agreements reflecting this limitation. “This proposal is based on the bureau’s preliminary findings – which are consistent with [its earlier] study – that pre-dispute arbitration agreements are being widely used to prevent consumers from seeking ...


May 16, 2016 - Inside the CFPB

Fair Lending in Mortgages Remains Key Issue for CFPB Enforcement

Mortgage lending continues to be a key priority for the CFPB’s Office of Fair Lending for supervision and enforcement, particularly Home Mortgage Disclosure Act data integrity and potential fair lending risks in the areas of redlining, underwriting and pricing, the bureau said in a new report. Last year, the bureau brought to an end two important public enforcement actions that had to do with mortgage lending. The first was a redlining case against Hudson City Savings Bank, which was required to pay almost $33 million in direct loan subsidies, funding for community programs and outreach, and a civil penalty. In this case, the CFPB accused Hudson City of providing unequal access to credit by structuring its business to avoid providing ...


May 16, 2016 - Inside the CFPB

More Homebuyers Reviewing Mortgage Disclosures, ALTA Finds

More homebuyers are reviewing their mortgage documents prior to their real estate closing under the new disclosure regime brought into the marketplace by the CFPB’s integrated disclosure rule, according to the results of a new closing survey by the American Land Title Association. However, there are still issues related to better educating consumers and in terms of the industry’s compliance. “While there remain challenges to complying with the regulation, title and settlement agents went to great lengths to prepare and train staff about the new process,” said Michelle Korsmo, ALTA’s chief executive officer. “The hard work of these professionals paid off as our survey found that 92 percent of surveyed homebuyers are taking time to review their mortgage documents before ...


May 16, 2016 - Inside the CFPB

Did CFPB Botch Another Attempt to Clarify its TRID Disclosure Rule?

Last week, in another apparent attempt to provide the mortgage lending industry with a bit more clarity when it comes to its TRID rule, the CFPB published on its website annotated versions of the Loan Estimate and Closing Disclosure that provide citations to the disclosure provisions in Chapter 2 of TILA referenced in the rule. However, neither of the two documents, which only number 14 pages between the two of them, appear to go anywhere near providing the kind of clarity the industry continues to hope for. According to Kristie Kully and David Tallman, both partners at the Mayer Brown law firm, these so-called “mapping forms” are unfortunately hamstrung by such extensive disclaimers that the bureau might as well have ...


May 16, 2016 - Inside the CFPB

SFIG’s Proposal on TRID Addresses Relevant Risks for RMBS: Moody’s

Analysts at Moody’s Investors Service believe that the Structured Finance Industry Group’s draft proposal on the CFPB’s integrated disclosure rule, otherwise known as TRID, generally is up to the task of addressing the relevant risks for U.S. residential mortgage-backed securities (RMBS), notwithstanding the uncertainty associated with the pending clarifying rulemaking from the bureau. The rule merges the mortgage disclosures mandated by the Truth in Lending Act and the Real Estate Settlement Procedures Act. “SFIG’s draft proposal to standardize the framework for reviewing and grading loans for TILA-RESPA Integrated Disclosure (TRID) rule compliance is adequate to identify those compliance risks that are likely to cause losses to RMBS trusts, aside from one grading provision with which we disagree,” said Moody’s Credit ...


May 12, 2016 - Inside Mortgage Finance

Quicken Loans CEO Says Company Will Not Settle DOJ False Claims Charges, Wants Trial by Jury

Quicken Loans CEO Bill Emerson ruled out any possibility of settlement with the Department of Justice over allegations of filing false claims on flawed FHA-insured mortgage loans, preferring instead a jury trial. During a recent interview with CNBC’s Squawk Box, Emerson said settlements are a business model that has worked well for the DOJ in its effort to recover taxpayer losses due to questionable FHA lending practices. Quicken Loans, however, will not cave in to agency…


May 6, 2016 - Inside FHA/VA Lending

VA Orders Special Forbearance for Borrowers in Flood Disaster Areas

The Department of Veterans Affairs has called upon holders of VA-guaranteed single-family mortgage loans to extend forbearance to distressed homeowners affected by the severe storms and flooding in Louisiana and Texas. In recent guidance, the VA described measures VA lenders may employ to provide relief to disaster-stricken homeowners. The agency recommended careful counseling to see whether borrower difficulties are related to the storms or have been the result of other events. If appropriate, prepayments may be reapplied to cure or prevent a borrower default. Servicers also may consider loan modification without VA’s prior approval if certain regulatory conditions are met. Although the holder of the loan is ultimately responsible for determining when to initiate foreclosure or complete termination action, the VA has requested a 90-day freeze on ...


May 6, 2016 - Inside Nonconforming Markets

Regulatory Issues Take Toll on Ocwen

The costs of ongoing monitoring mandated by various regulators contributed to the large $111.2 million net loss posted by Ocwen Financial in the first quarter of 2016 that included $30.0 million in monitoring costs. Ocwen continues to make progress toward decreasing settlement-related costs though regulatory pressures persist. Ocwen’s monitor costs were...


May 6, 2016 - Inside Nonconforming Markets

Subprime Servicing Drops, Regulatory Issues Don’t

Ongoing declines in the volume of subprime mortgages outstanding have done little to limit regulatory issues involving subprime servicing. An estimated $287.0 billion in subprime mortgages were outstanding as of the end of the first quarter of 2016, down 16.3 percent from the first quarter of 2015, according to a new ranking and analysis by Inside Nonconforming Markets. The Consumer Financial Protection Bureau released...[Includes one data table]


May 6, 2016 - Inside MBS & ABS

Developments, Delays, Oral Arguments in Fannie, Freddie Shareholder Lawsuits

Private shareholder lawsuits against the U.S. Treasury’s net worth sweep of Fannie Mae and Freddie Mac profits are inching forward, including a squabble over the Federal Housing Finance Agency’s bid to consolidate several cases in one court. The Federal Housing Finance Agency said the proposed transfer would prevent future “copycat” cases and ensure a more consistent ruling across the board by having all of the cases heard in one court instead of scattered in different jurisdictions throughout the country. Private plaintiffs, including Tim Pagliara, director of shareholder group Investors Unite, filed...


May 2, 2016 - Inside the CFPB

Other News in Brief

Mortgage Warehouse Volume at Horizon Bancorp Declines in First Quarter, TRID Remains an Issue. Horizon Bancorp announced recently that its mortgage warehouse lending efforts were down in the first quarter of 2016. The bank had $119.88 million in mortgage warehouse loans on its balance sheet at the end of the first quarter of 2016, down 17.2 percent from the previous quarter and down 33.0 percent from the first quarter of 2015.... Flagstar Boosts Originations and Income in 1Q16, Is Comfortable with TRID. Flagstar Bancorp reported an increase in originations and net income for the first quarter of 2016 with company executives noting that the bank is comfortable with the TRID mortgage disclosure requirements...


May 2, 2016 - Inside the CFPB

CFPB Solicits Comment on Sample Periodic Statements in Bankruptcy

The CFPB recently reopened the public comment period on whether mortgage servicers should be required to provide periodic statements for borrowers who have filed for bankruptcy. Specifically, the bureau is seeking public input on the consumer testing it did on its proposed sample periodic statement forms. Back in January 2013, the bureau issued its two mortgage servicing final rules. The agency clarified and revised those rules during the summer and fall of 2013 in two packages of amendments. Then in October 2013, the CFPB clarified compliance requirements in relation to successors in interest, early intervention requirements, bankruptcy law, and the Fair Debt Collection Practices Act (FDCPA), through an interim final rule (IFR) and a contemporaneous compliance bulletin. Among other things,...


May 2, 2016 - Inside the CFPB

CHLA Calls for Balanced Treatment Of Nonbank Mortgage Lenders

In the continuing wake of industry concerns about the TRID disclosure rule and worries about large retroactive fines, the Community Home Lenders Association says the CFPB should provide more balanced regulatory and enforcement policies toward smaller nonbank mortgage lenders and improve compliance guidance and due process. Asserting that nonbank mortgage lenders, including community-based lenders, have recently “led the way” in providing access to mortgage credit and providing more personalized loan servicing, the CHLA said “any regulatory policies that have the effect of imposing a disproportionate compliance burden on smaller lender/servicers can accelerate industry consolidation – which in turn can result in fewer consumer choices and less personalized service.” The trade group had three main recommendations for the bureau, the first of ...


May 2, 2016 - Inside the CFPB

It Was Thought TRID ‘Scratch & Dent’ Market Would Fade. It Hasn’t

The secondary market for mortgages with TRID errors has yet to lose any steam, even though it was anticipated that the action would fade by now. That’s the assessment of Jeff Bode, CEO of Mid America Mortgage, Addison, TX, one of the largest investors in loans with TRID problems. “It’s still pretty solid,” Bode told IMFnews, an affiliated publication. “But I don’t see how much longer it can last.” Bode noted that some of the mortgages he’s reviewing have errors that are so minor he’s surprised that secondary market investors are balking at them in the first place. Mid America buys such mortgages and “makes the cures” itself, the CEO noted. A secondary market for mortgages with TRID errors – jumbos ...


May 2, 2016 - Inside the CFPB

TRID Architect Provides Inside Perspective on Pending Rule

Both the mortgage industry and the CFPB itself may have been caught a bit flat-footed when it came to fully grasping the significance and complexity of the bureau’s TRID integrated disclosure rule, according to one of the individuals intimately associated with drafting the controversial regulation. “TRID is a huge rule, about 1,900 pages of extremely detailed twists and turns. It affects every single aspect of the origination and closing process, as well as liability for lenders and the secondary market,” former bureau official Richard Horn, now an attorney in private practice, told Inside the CFPB. “I think many in the industry had to play catch up these past seven months, trying to grasp the far reaches and complexity of this ...


May 2, 2016 - Inside the CFPB

Life Under TRID: CFPB Relents on Guidance, Preps to Issue Another Rule

After months of hearing mortgage banking and real estate executives gripe about problems tied to the TRID integrated disclosure rule, the CFPB last week signaled its intention to clarify the controversial measure, which became effective in early October. According to a letter from CFPB Director Richard Cordray to industry trade groups, the agency will issue new rulemaking tied to the TRID disclosure regime that will provide greater certainty and clarity. Cordray – who has been lambasted by the industry about the integrated disclosure rule for months – noted in the letter: “We recognize that the implementation of the Know Before You Owe rule poses many operational challenges. We also recognize that implementation is particularly challenging because of the diversity of the participants ...


April 29, 2016 - Inside The GSEs

GSE Shareholders See Bright Spot In Recent Legal Developments

Recent legal developments bode well for GSE shareholder lawsuits, according to one of the attorneys involved in the Perry Capital LLC v. Lew et al case where shareholders question the validity of the Treasury sweep of the profits of Fannie Mae and Freddie Mac. The D.C. Circuit Court heard oral arguments in the case on April 15 before three federal judges. The oral arguments took place as part of the appeal of the Fairholme Funds case dismissal in 2014, in which investors argued that the Treasury sweep violated the Housing and Economic Recovery Act. Hamish Hume, partner with Boies Schiller & Flexner, who argued before the panel of judges, said...


April 28, 2016 - Inside Mortgage Finance

New York Supreme Court Reverses Ruling in Foreclosure Case, Endorsing Lenders’ Use of Electronic Note Signings

The New York State Supreme Court recently reversed a ruling in a foreclosure case, providing a favorable decision for lenders and servicers. New York Community Bank v. Daphne McClendon involved a foreclosure that was initiated in 2012. The mortgage in question was originated in 2008 by AmTrust Bank for $544,000. The note accompanying the mortgage was signed by electronic signature. The borrower challenged...


April 21, 2016 - Inside Mortgage Finance

FinCEN Increases Scrutiny of Non-Mortgage Purchases of Luxury Homes As Part of Real Estate-Related AML Effort

A pilot effort by the Treasury Department’s Financial Crimes Enforcement Network is underway in New York City and Miami to track suspicious “all cash” purchases of high-end residential properties as part of the government’s anti-money laundering (AML) enforcement. In remarks during a recent AML conference in Florida, FinCEN Director Jennifer Shasky Calvery said geographic targeting orders (GTOs) were issued by the agency in January this year and went into effect on March 1. They require identification of high-end cash buyers to ensure luxury residences purchased with cash are not masking money laundering activities. Specifically, U.S. title insurance companies are temporarily required...


April 21, 2016 - Inside Mortgage Finance

New Jersey Nonbank Pays $113 Million to Settle FHA Quality Control, Underwriting and Reporting Issues

Freedom Mortgage Corp. has agreed to pay the federal government $113 million to resolve alleged violations of the federal False Claims Act and FHA requirements in connection with the origination of FHA-insured single-family mortgages. The April 15 settlement agreement between the New Jersey-based mortgage lender and the Department of Justice comes in the wake of a record $1.2 billion settlement between DOJ and Wells Fargo, which earlier admitted to false certification of defective mortgages for FHA insurance and failure to file timely reports on several thousand loans that were materially defective or badly underwritten. Like Wells Fargo, Freedom Mortgage failed...


April 18, 2016 - Inside the CFPB

Industry Attorneys Think PHH Corp. Will Prevail in Dispute With CFPB

Many mortgage industry attorneys seem convinced that PHH Corp. will succeed – at least at the appellate court level – in defying the CFPB in its ongoing legal dispute with the bureau. The crux of the dispute is the bureau’s assertion that PHH violated the Real Estate Settlement Procedures Act and harmed consumers through a mortgage insurance kickback scheme tied to a captive MI. Last week, the U.S. Court of Appeals for the District of Columbia heard oral arguments in the case, PHH Corp. v CFPB, and the day did not go well for the bureau. Former CFPB enforcement attorney Jennifer Lee, now a partner with the Dorsey & Whitney law firm in Washington, DC, succinctly summarized the tough day the bureau ...


April 18, 2016 - Inside the CFPB

Bureau Rules Have Driven Small Banks Out of Mortgage Business

Former Federal Trade Commission official Todd Zywicki had a blunt message for the U.S. Senate Banking, Housing and Urban Affairs Committee recently when it comes to the CFPB and its voluminous new mortgage rules: Many smaller banks have simply chosen to exit the residential finance sector rather than bear the increased regulatory costs and risks. The former director of policy planning at the FTC cited a survey conducted by George Mason University’s Mercatus Center which found “64 percent of small banks reported that they were making changes to their mortgage offerings because of [the] Dodd-Frank [Act], and 15 percent said that they had either exited or were considering exiting residential mortgage markets entirely.” Also, almost 60 percent of small banks ...


April 15, 2016 - Inside The GSEs

Judge Releases Protected Documents in GSE Court Case

This week, a judge removed the protective order on seven documents related to the U.S. Treasury’s sweep of GSE profits, revealing what shareholders and industry groups have been arguing for years: that Fannie Mae and Freddie Mac were in a position to post profits on a sustained basis. In a whirlwind of court activity over the past month involving GSE shareholders, Court of Federal Claims Judge Margaret Sweeney decided on April 12 to release certain documents that appellants in Fairholme Funds, Inc. et. al. v. United States and Perry Capital v. Lew, moved to be made public. This is ahead of the D.C. Circuit schedule oral argument for the Perry case on April 15 and it intensified talks of government corruption and false claims of protecting taxpayers via the sweep.


April 15, 2016 - Inside MBS & ABS

Goldman Sachs Settles Pre-Crisis Non-Agency MBS Issues with DOJ, States for $5.06 Billion

The Department of Justice helped lead other federal and state entities in a $5.06 billion settlement with Goldman Sachs. The settlement announced this week involves non-agency MBS underwritten by Goldman between 2005 and 2007. The charges were centered on representations made by Goldman to investors in about 530 non-agency MBS. The offering documents for the MBS stated that mortgages in the deals were originated “generally in accordance with the loan originator’s underwriting guidelines,” other than possible situations where “when the originator identified ‘compensating factors’ at the time of origination.” Findings by third-party due diligence firms helped...


April 14, 2016 - Inside Mortgage Finance

Wells Fargo Agrees to Pay $1.2 Billion to Resolve Charges Of Improper FHA Lending Practices Over 9-Year Period

Wells Fargo last week reached an agreement to pay $1.2 billion to the federal government to resolve certification and reporting violations in connection with FHA-insured loans. The settlement is the largest recovery for loan-origination violations in FHA history, according to Housing and Urban Development Secretary Julian Castro. The April 8 court filing details an agreement in principle, which Wells Fargo announced in February, that resolves not only a pending lawsuit filed by the U.S. Attorney for the Southern District of New York, but also a number of potential claims dating as far back as 15 years in some cases, according to a statement issued by Wells Fargo. According to the settlement, Wells Fargo “admitted...


April 14, 2016 - Inside Mortgage Finance

CFPB Faces Hostile Questions in Dispute with PHH; Appeal to SCOTUS Likely by Whomever Loses the Case

The mortgage industry found some justification to hope for a return to a more traditional interpretation of the Real Estate Settlement Procedures Act, after the Consumer Financial Protection Bureau took some judicial fire during oral arguments early this week in its dispute with PHH Corp. over the company’s captive mortgage reinsurance activity. The crux of the dispute is the bureau’s assertion that PHH violated RESPA and harmed consumers through a mortgage insurance kickback scheme tied to a captive MI company. Virtually all the major mortgage lenders used similar captive reinsurance entities prior to the financial collapse. In the run-up to this week’s oral arguments before the U.S. Court of Appeals for the District of Columbia, the justices seemed...


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