The U.S. Court of Appeals for the District Columbia recently issued a stay against a $109.2 million fine levied by the bureau against PHH Corp. related to the lender’s captive mortgage insurance activities. The bureau had initiated an administrative proceeding against the nonbank lender, accusing it of harming consumers through a mortgage insurance kickback scheme tied to a captive MI. A judge agreed and recommended a penalty of just $6.4 million, which the CFPB ignored and jacked up to $109.2 million, a figure the regulator argued represented all the MI premiums received after July 2008. What startled the industry was the CFPB’s decision to throw out previous guidance from the Department of Housing and Urban Development under which PHH and ...