Over the past few years, the Consumer Financial Protection Bureau (“CFPB”) has taken center stage for its aggressive enforcement posture.  While I have major disagreements with the CFPB’s regulation/guidance through enforcement practice, particularly as it impacts the real estate title industry given the fact that the vast majority of title agencies are small businesses that do not have the resources to hire in house compliance officers or hire expensive outside counsel, its most recent enforcement action seems to be misunderstood.