PHH Corp. v. Consumer Financial Protection Bureau (D.C. Circuit)

The Consumer Financial Protection Bureau concluded in an internal agency enforcement proceeding that certain defendants violated the Real Estate Settlement Procedures Act and required them to pay $109 million in disgorgement. On behalf of the US Chamber of Commerce, we filed an amicus brief supporting the defendants, pointing out that the CFPB had violated due process by departing from its previously settled interpretation of RESPA and using its new interpretation to sanction the defendants.