Third Cir. Says Statute of Limitations Not Extended for Class Action

[Editor's note: Rachel J. Schwartz of Carlton Fields in New York represents property and casualty insurance industry clients in litigation, and counsels them on varied coverage matters, including coverage disputes arising under Commercial General Liability and Directors & Officer policies.]

In 2005 and 2006, Christopher Blake and James Orkis took out mortgages from JP Morgan to buy homes. Then in 2013, they filed a class action against JP Morgan under the Real Estate Settlement and Procedures Act (RESPA), alleging a scheme to refer homeowners to mortgage insurers/reinsurers in exchange for streams of kickbacks.

RESPA has a one-year statute of …