CFPB as HUD: Another Section 8 Consent Order Displays CFPB’s RESPA Approach | Morrison & Foerster LLP – JDSupra

In the Consent Order, the CFPB claimed that Lighthouse entered into marketing services agreements (“MSAs”) for advertising with parties such as real estate brokers, and made payments related to these agreements based on the “volume or value of business referred” by such counterparties. As a result of this practice, the CFPB alleged that Lighthouse violated RESPA both for entering into the MSAs and for varying the fees it paid based on the referral of business provided by the counterparties.

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