Consent Order Quicken Loans, Inc. and another Reverse Mortgage, LLC

Consent Order Quicken Loans, Inc. and another Reverse Mortgage, LLC

Date: 04/20/2018
Organization: Division of Banks
Docket Number: 2017-005
Location: Detriot, Michigan and north park, Ca

WHILE, a study of Quicken Loans was conducted pursuant to General Laws chapter 255E, part 8, at the time of August 2, 2016, to evaluate Quicken Loans’ lending performance under Mortgage Lender Community Investment standards described when you look at the Division’s legislation 209 CMR 54.00 et seq.;

WHILE, the Report of Examination (Report) given pursuant towards the Division’s examination of Quicken Loans as of August 2, 2016 alleged significant non-compliance with relevant Massachusetts and federal statues, guidelines, and laws regulating the conduct of the involved with the company of a home loan loan provider in Massachusetts with regards to Quicken Loans’ reporting of particular information elements underneath the Home Mortgage Disclosure Act (HMDA);

WHILE, an study of ORM ended up being conducted pursuant to General Laws chapter 255E, section 8, as of November 6, 2017, to assess compliance that is ORM’s the legal guidelines relevant to its company;

WHILE, the Division has made no discovering that either business has interpreted and used law that is such bad faith and for the goal of deliberately avoiding its reporting responsibilities under HMDA; and

WHILE, the Division and Quicken Loans now look for to solve by shared contract the issues identified within the Report, therefore the Division and ORM now look for to solve by shared contract comparable issues arising regarding the the examination that is referenced of.

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Consent Order

NOW COME the events within the matter that is above-captioned the Division and also the organizations, and stipulate and agree as follows:

  1. The recitals set forth above are incorporated and produced component with this purchase.
  2. As a result into the Report, Quicken Loans has implemented specific modifications to its policies and procedures for collection and reporting of HMDA information, such that it treats consumer that is certain as applications for HMDA-reporting purposes at an early on phase than was in fact the scenario ahead of the issuance regarding the Report. a detail by detail description of quicken Loans’ policies and procedures, changed in response to your Report, and of ORM’s parallel policies and procedures for collection and reporting of HMDA information was supplied confidentially towards the Division on paper, contemporaneous with this particular Consent purchase (Policy Description).
  3. The businesses shall remit an aggregate repayment in the quantity of 2 hundred and fifty thousand bucks ($250,000). The businesses shall remit re payment in complete within the quantity suggested above within seven (7) times of the execution of this Consent Order, payable towards the “Commonwealth of Massachusetts,” because of the performed copy regarding the Consent Order, into the workplace for the Commissioner of Banks, 1000 Washington Street, tenth Floor, Boston, Massachusetts 02118.
  4. The companies each shall engage an independent auditing firm (Auditing Firm) to conduct an audit review of the continued implementation of the policies and procedures outlined in Paragraph 2 of this Consent Order and in the Policy Description and any corrective actions required of Quicken Loans by the Report within thirty (30) days of the effective date of this Consent Order. The Auditing Firm shall issue reports (Audit Reports) assessing all the ongoing companies’ compliance with such policies and procedures with regards to all of their yearly HMDA information filings for Calendar Years 2017 and 2018, along with conformity during each quarter during 2018. The Audit that is first Report addressing season 2017 while the very very first and 2nd quarters of 2018, will be released because of the Auditing Firm into the Division by August 31, 2018. The Audit Report since the 3rd quarter of 2018 will probably be granted because of the Auditing company into the Division by November 30, 2018. The Audit Report since the 4th quarter of 2018 will be given by the Auditing company to your Division by February 28, 2019, while the Audit Report addressing season 2018 will be given by the Auditing company towards the Division by March 29, 2019.
  5. The companies each shall prior obtain the written approval through the Division concerning the range of this review before reviews are initiated . The Audits will be carried out because of the Auditing Firm formerly decided because of the Division.
  6. absolutely Nothing in this order that is consent such as the modifications created by Quicken Loans described above while the re re re payment established in paragraph 3, will be construed as an admission, concession, or contract that either or both associated with the Companies didn’t conform to any relevant legislation, guideline, regulation, or regulatory bulletin to that your organizations are topic and that is enforceable by the Division.
  7. The businesses each shall establish, implement, keep, and sporadically upgrade operating policies and training procedures to ensure all relevant workers associated with the collection and reporting of HMDA information have a very comprehensive comprehension of the policies and procedures described in Paragraph 2 of the Consent Order and when you look at the Policy definition. Such training shall fundamentally make sure the appropriate execution and execution of all of the revised policies and procedures used pursuant to Paragraph 2 with this order that is consent. Such policies and training procedures must certanly be made to make sure all appropriate training supplied to employees is tracked and documented.
  8. Each shall furnish written progress reports to the Division, which shall address the following: a on the thirtieth (30th) day after the end of each calendar quarter following the date of this Consent Order, beginning with the calendar quarter ending June 30, 2018, the companies. A description regarding the kind, content, and method of any actions taken up to deal with each portion of this order that is consent the outcomes thereof; and b. Penned findings ready by each Company explaining management’s and staff persons’ adherence to your policies and procedures referred to in Paragraph 2 for this order that is consent when you look at the Policy explanation and also to relevant statutes, laws, and guidelines linked to the issues which can be the topic of this Consent purchase, also a description of any functional modifications implemented during such quarter that are meant to enhance such Company’s conformity condition in Massachusetts in addition to outcomes thereof.
  9. The reporting requirement into the Division referenced in Section 8 for this Consent purchase shall remain in place and shall never be amended or rescinded with no prior written modification, termination, or suspension system associated with relevant supply for this order that is consent the Commissioner. Upon the demand of either business, the Division may end this reporting requirement at its discretion.
  10. Nothing in this Consent Order shall be construed as allowing the firms to break any legislation, guideline, legislation, or regulatory bulletin to that the businesses are topic.
  11. Failure of a business to conform to the regards to this Consent Order shall represent grounds for permit suspension and/or revocation of such Company, or any other formal regulatory action against such business pursuant to relevant conditions regarding the General Laws of this payday loans Gloucestershire Commonwealth of Massachusetts.
  12. In consideration for this Consent purchase, topic to Paragraphs 10 and 11, the Division agrees never to pursue formal measures, in accordance with this matter, to suspend or revoke either Company’s mortgage company permit or even just simply take every other formal or other action against either business with regards to the things included in this Consent purchase.
  13. This Order that is consent shall effective instantly upon the date of their issuance.
  14. The conditions with this Consent purchase shall remain effective and enforceable except into the degree that, and until such time since the Commissioner or perhaps a court of competent jurisdiction modifies, terminates, suspends, or sets apart any supply with this order that is consent.
  15. The organizations’ rights and responsibilities under this Consent purchase are split from one another, and shall endure individually in case, among other opportunities, any particular one business shall not any longer be associated with one other or shall cease to be always a licensee.
  16. This Consent Order and also the Consent contract are the entire papers representing the quality with this matter. There aren’t any other agreements involving the Division and either regarding the businesses.

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