In late April, the CFPB issued a final rule governing the administration of its Civil Penalty Fund, along with proposed revisions to that rule. Among the highlights of the final rule is that a victim is eligible for payment from the fund if a final order in a bureau enforcement action imposed a civil penalty for the violation or violations that harmed the victim. That means that payments from the fund would only be made to compensate victims for the harms they suffered from a violation for which penalties were...