Considerations And Consequences From CFPB's 1st Appeal

Law360, New York (June 15, 2015, 12:04 PM EDT) -- The Consumer Financial Protection Bureau issued its first appellate decision on June 4, leaving little by way of protection for targets of its administrative enforcement proceedings. Targets and subjects of a CFPB enforcement investigation or administrative proceeding, and those who represent targets and subjects that are respondents in such a proceeding, should consider implementing more robust procedural best practices.


On June 4, the CFPB issued its first decision on an appeal of an administrative law judge's decision in a CFPB administrative enforcement proceeding.[1] The ALJ decision was appealed both by the respondent, PHH Corp. and its affiliates[2], and by the CFPB's enforcement...

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