Richard J. Andreano 


The recent written administrative appeal decision of CFPB Director Cordray against PHH in the captive reinsurance context finally articulated the regulator’s position regarding the 8 (c) (2) “services rendered” exception first mentioned in the Lighthouse Title Consent Order. Although the PHH Decision is being appealed on multiple grounds, learn how it provides critical lessons for marketing services agreements and other relationships premised on the provision of goods or services to minimize exposure for RESPA liability arising from illegal referral fees. 

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Related Practice

Mortgage Banking