As we wrote previously, the CFPB had issued a final ruling in 2015 that PHH Corp. (PHH) violated RESPA by doing business exclusively with mortgage insurance companies that agreed to purchase reinsurance from a wholly-owned PHH subsidiary. The CFPB concluded the reinsurance premiums constituted illegal kickbacks for PHH's referrals of the initial mortgage insurance business in violation of Section 8(a), which prohibits giving or receiving any "thing of value" in return for settlement service business. The CFPB required PHH to disgorge all of the reinsurance premiums its subsidiary received from mortgage insurers since 2008, totaling $109 million as compared to the $6 million disgorgement order from the administrative law judge.