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Preview of a Post-Chevron World: The Seventh Circuit Upholds Regulation B's Discouragement Prohibition as Consistent with ECOA

With Loper Bright’s recent death blow to Chevron deference, some commentators have been predicting substantial constriction of the administrative state and the narrowing or limiting of the powers of federal regulators. For...more

FDIC's Continued Focus on RESPA Section 8 Violations: What Bank and Non-Bank Lenders Should Know

It is no secret that the Federal Deposit Insurance Corporation (FDIC) actively monitors its banks for compliance with Section 8 of the Real Estate Settlement Procedures Act (RESPA Section 8). However, in its March 2024...more

CFPB Targets Mortgage Closing Costs as Junk Fees

On March 8, 2024, the CFPB issued a blog post signaling a new front in its focus on “junk fees”—mortgage closing costs. Notably, the CFPB suggests that title insurance, credit report and appraisal, origination, and other...more

CFPB Guidance on Digital Comparison-Shopping Tools, Round Two

On February 29, 2024, the CFPB issued Consumer Financial Protection Circular 2024-01: Preferencing and steering practices by digital intermediaries for consumer financial products or services. The circular provides guidance...more

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