Background PHH is not a major Wall Street bank, but is nonetheless a substantial mortgage lender with over a billion-dollar market cap. In January 2014, the CFPB filed a Notice of Charges accusing PHH and four of its affiliates with violating the Real Estate Settlement Procedures Act ("RESPA") by accepting payments from mortgage insurers to whom a PHH mortgage lender referred mortgage insurance business. The payments were in the form of reinsurance premiums, and were paid to PHH affiliates that are in the business of providing reinsurance. There was no allegation that the payments were outside industry norms, or that the reinsurance was illusory, or that the mortgage insurers charged borrowers above-market rates. The CFPB ultimately ruled, however, that the receipt of such payments violated RESPA because they were part of a referral arrangement—absent payment of reinsurance premiums to PHH affiliates, PHH's mortgage lender would not refer business to the mortgage insurers.