"Although most consumers actively shop for a home and some shop for a mortgage, very few actually shop for settlement services." Following the housing bubble's calamitous burst, the federal rules regulating joint ventures did not change. However, the agency enforcing those rules did shift, from U.S. Housing and Urban Development to the newly formed Consumer Finance Protection Bureau, which began to announce RESPA enforcement actions. Federal appeals courts pushed back against some actions, including the case against PHH (which Ocwen bought in 2018). Future U.S. Supreme Court Justice Brent Kavanaugh authored a 2018 D.C. Court of Appeals ruling that vacated the $109 million civil penalty, declaring CFPB's executive authority "a grave threat to individual liberty." "When measured in terms of unilateral power, the Director of the CFPB is the single most powerful official in the entire U.S. government, other than the President," Kavanaugh wrote.