The D.C. Circuit Court of Appeals’ en banc ruling in PHH Corp. v. CFPB might have restored previous federal interpretation of RESPA. But states’ interpretation of lawful and unlawful inducements might not be in line with the federal view.
In a speech Tuesday before the New York City Bar Association, New York Department of Financial Services Superintendent Maria Vullo sought to clarify her agency’s position on inducements.
Among her views: Gift cards are not marketing. Read on for more details.
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