In the first-ever appeal from the decision of an administrative law judge, Consumer Financial Protection Bureau Director Richard Cordray imposed a $109 million award against PHH Mortgage — far more than the $6.4 million awarded by the ALJ.
Although not a decision involving marketing, every lender should take the time to carefully review the PHH reinsurance case.
Beyond demonstrating the risk of an internal CFPB administrative appeal, Cordray made two specific and ominous rulings.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide.
Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.
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