In a decision issued earlier this summer, the U.S. Court of Appeals for the Seventh Circuit vacated the district court’s order awarding restitution, mandating civil penalties, and issuing an injunction in an action brought by the CFPB against two mortgage-assistance relief companies and four lawyers associated with the companies.  The decision imposes significant limitations on

The Office of the Comptroller of the Currency recently issued a revised Policies and Procedures Manual (PPM) for assessing civil money penalties (CMP).  The PPM applies to CMPs assessed against all national banks, federal savings associations, federal branches and agencies licensed by the OCC, and institution-affiliated parties.  It also applies to bank service companies and