Consent Order Quicken Loans, Inc. plus one Reverse Home Loan, LLC

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

WHILE, an study of Quicken Loans was carried out pursuant to General Laws chapter 255E, part 8, as of August 2, 2016, to evaluate Quicken Loans’ lending performance under Mortgage Lender Community Investment standards described within the Division’s legislation 209 CMR 54.00 et seq.;

WHEREAS, the Report of Examination (Report) given pursuant towards the Division’s study of Quicken Loans as of August 2, 2016 alleged non-compliance that is substantial relevant Massachusetts and federal statues, guidelines, and laws regulating the conduct of the involved in the business enterprise of a home loan loan provider in Massachusetts with regards to Quicken Loans’ reporting of specific information elements beneath the Residence Mortgage Disclosure Act (HMDA);

WHILE, a study of ORM was carried out pursuant to General Laws chapter 255E, part 8, at the time of November 6, 2017, to assess compliance that is ORM’s the legal guidelines relevant to its company;

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

WHEREAS, the Division and Quicken Loans now look for to eliminate by shared agreement the things identified within the Report, plus the Division and ORM now look for to solve by shared contract comparable things arising regarding the the referenced study of ORM.

Dining dining dining Table of articles

Consent Order

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

  1. The recitals set forth above are incorporated and made a component with this purchase.
  2. In reaction to your 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 a youthful phase than was indeed the actual situation ahead of the issuance for the Report. a description that is detailed of Loans’ policies and procedures, changed in response towards the Report, as well as ORM’s parallel policies and procedures for collection and reporting of HMDA information happens to be supplied confidentially into the Division on paper, contemporaneous using this Consent purchase (Policy Description).
  3. The businesses shall remit an aggregate repayment in the total amount of 2 hundred and fifty thousand bucks ($250,000). The businesses shall remit re payment in complete when you look at the quantity suggested above within seven (7) times of the execution of the Consent Order, payable towards the “Commonwealth of Massachusetts,” because of the executed copy associated with the Consent Order, into the workplace of this 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 each one of the organizations’ 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 probably be given because http://speedyloan.net/uk/payday-loans-ess of the Auditing company to your Division by August 31, 2018. The Audit Report within the 3rd quarter of 2018 will probably be granted because of the Auditing company towards the Division by November 30, 2018. The Audit Report since the quarter that is fourth of will be released because of the Auditing company into the Division by February 28, 2019, in addition to Audit Report addressing season 2018 will probably be granted by the Auditing company towards the Division by March 29, 2019.
  5. The businesses each shall receive the prior written approval through the Division concerning the range associated with review before reviews are initiated . The Audits will probably be conducted because of the Auditing Firm formerly decided by the Division.
  6. absolutely Nothing in this Consent purchase, such as the modifications produced by Quicken Loans described above as well as the re re payment set forth in paragraph 3, will probably be construed being an admission, concession, or contract that either or each regarding the Companies did not conform to any relevant legislation, guideline, legislation, or regulatory bulletin to that the organizations are topic and that is enforceable by the Division.
  7. The businesses each shall establish, implement, keep, and occasionally upgrade running policies and training procedures to ensure all applicable workers involved with the collection and reporting of HMDA information have a very understanding that is comprehensive of policies and procedures referred to in Paragraph 2 of the Consent Order and into the Policy explanation. Such training shall always guarantee the proper execution and execution of most revised policies and procedures used pursuant to Paragraph 2 with this Consent purchase. Such policies and training procedures should be made to make sure all appropriate training provided to workers 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 of this kind, content, and method of any actions taken fully to deal with each part of this order that is consent the outcome thereof; and b. Penned findings ready by each Company explaining management’s and staff persons’ adherence to the policies and procedures referred to in Paragraph 2 with 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 main topic of this Consent purchase, along with a description of any functional modifications implemented during such quarter that are designed to enhance such Company’s conformity symptom in Massachusetts while the outcomes thereof.
  9. The reporting requirement towards the Division referenced in Section 8 with 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 the relevant supply with this order that is consent the Commissioner. Upon the demand of either Company, the Division may end this reporting requirement at its discernment.
  10. absolutely Nothing in this Consent purchase shall be construed as allowing the businesses to break any legislation, guideline, legislation, or bulletin that is regulatory that your businesses are subject.
  11. Failure of a business to conform to the regards to this Consent purchase shall represent grounds for permit suspension and/or revocation of such business, or any other formal action that is regulatory such business pursuant to relevant conditions for the General Laws associated with Commonwealth of Massachusetts.
  12. In consideration with this Consent purchase, subject to Paragraphs 10 and 11, the Division agrees to not pursue formal measures, in accordance with this matter, to suspend or revoke either Company’s mortgage company permit or even simply just take just about any formal or any other action against either business with regards to the things included in this order that is consent.
  13. This Order that is consent shall effective instantly upon the date of their issuance.
  14. The conditions for this Consent Order shall remain effective and enforceable except towards the degree that, and until such time since the Commissioner or a court of competent jurisdiction modifies, terminates, suspends, or sets apart any supply for this order that is consent.
  15. The organizations’ legal rights and responsibilities under this Consent purchase are split from one another, and shall endure individually in case, among other opportunities, this one business shall no further be associated with one other or shall stop to become a licensee.
  16. This Consent Order and also the Consent contract are the whole papers representing the quality with this matter. There aren’t any other agreements amongst the Division and either regarding the businesses.
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