The D.C. Circuit Court’s decision in PHH Corp., et al. v. Consumer Financial Protection Bureau deals a major blow to the CFPB and represents a victory for financial services industry. Although the Court’s constitutional holding may dominate the headlines, the most significant aspects of the Court’s decision for the industry are the limits on the CFPB’s ability to retroactively apply new interpretations of laws and the limits imposed by statutes of limitations on CFPB administrative enforcement proceedings. The first should ensure that industry has fair notice about new or revised CFPB interpretations of law before the Bureau takes enforcement actions. The second should substantially limit industry’s exposure to penalties and restitution for violations that occurred many years ago.  In this client alert, we provide a preliminary assessment of the Court’s decision and what it may mean for consumer financial services industry participants.