On October 25, 2016, CFPB Director Richard Cordray delivered remarks to the Mortgage Bankers Association regarding the recovery of the mortgage industry.  Director Cordray discussed several of the CFPB’s mortgage-related initiatives, including the reporting requirements under Regulation C, which implements the Home Mortgage Disclosure Act, and the “Know Before You Owe” mortgage disclosure rule.

Director Cordray also addressed the D.C. Circuit’s recent opinion in PHH Corp. et al. v. CFPB.  He emphasized that the Bureau “respectfully disagrees” with the decision and will seek further review.  Until the matter is final, Director Cordray indicated that the CFPB will continue to consider how best to apply the Real Estate Settlement Procedures Act “to specific factual situations as we always do,” and in particular will continue to adhere to its 2015 bulletin regarding marketing services agreements.