As we previously covered here, on June 6, 2015, Director Richard Cordray issued the first appellate decision of an order of an administrative law judge imposing a $6.4 million disgorgement order on PHH Corporation, a mortgage lender, arising out of alleged RESPA anti-kickback violations. Under the Dodd-Frank Act, the director of the CFPB hears appeals from ALJ decisions in administrative enforcement proceedings. In his decision, Director Cordray affirmed the basic findings of the ALJ but increased the amount of the disgorgement order to $109 million, based, in part, on his finding that the agency is not bound by the statute of limitations in administrative enforcement proceedings. PHH appealed the appellate decision to the D.C. Circuit Court of Appeals. On August 3, 2015, the D.C. Circuit stayed the fine pending appeal.