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 quantity: 2017-005
Location: Detriot, Michigan and north park, Ca

WHILE, a study of Quicken Loans was carried out 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 within the Division’s legislation 209 CMR 54.00 et seq.;

WHILE, the Report of Examination (Report) given pursuant to your Division’s study 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 business enterprise of a home loan loan provider in Massachusetts with regards to Quicken Loans’ reporting of particular information elements beneath the Residence Mortgage Disclosure Act (HMDA);

WHILE, an study of ORM ended up being carried out pursuant to General Laws chapter 255E, part 8, at the time of November 6, 2017, to assess ORM’s compliance with the regulations relevant to its company;

WHILE, the Division has made no discovering that either business has interpreted and used such legislation in bad faith and for the objective of deliberately avoiding its reporting obligations under HMDA; and

WHILE, the Division and Quicken Loans now look for to solve by shared contract the things identified into the Report, as well as the Division and ORM now look for to solve by shared contract comparable things arising regarding the the referenced study of ORM.

dining dining Table of articles

Consent Order

NOW COME the events into the above-captioned matter, the Division together with businesses, and stipulate and agree as follows:

  1. The recitals set forth above are incorporated and produced right component with this Order.
  2. In reaction towards the Report, Quicken Loans has implemented specific modifications to its policies and procedures for collection and reporting of HMDA information, such that it treats specific customer requests as applications for HMDA-reporting purposes at a youthful phase than have been the way it is before the issuance associated with Report. a description that is detailed of Loans’ policies and procedures, changed in response to your Report, as well as ORM’s parallel policies and procedures for collection and reporting of HMDA information happens to be supplied confidentially towards the Division on paper, contemporaneous with this specific Consent purchase (Policy Description).
  3. The firms shall remit an aggregate repayment in the total amount of 2 hundred and fifty thousand bucks ($250,000). The firms shall remit re re payment in full when you look at the quantity indicated above within seven (7) times of the execution for this Consent Order, payable to your “Commonwealth of Massachusetts,” because of the performed copy associated with the Consent Order, to your Office associated with Commissioner of Banks, 1000 Washington Street, tenth Floor, Boston, Massachusetts 02118.
  4. Within thirty (30) times of the effective date of the Consent Order, the businesses each shall engage an unbiased auditing firm (Auditing Firm) to conduct an review report on the continued utilization of the policies and procedures outlined in Paragraph 2 of the Consent Order and into the Policy explanation and any corrective actions needed of Quicken Loans by the Report. The Auditing Firm shall issue reports (Audit Reports) assessing all the organizations’ conformity with such policies and procedures pertaining to all of their annual HMDA data filings for Calendar Years 2017 and 2018, along with conformity during each quarter during 2018. The very first Audit Report, addressing season 2017 in addition to very very very first and 2nd quarters of 2018, will probably be granted by the Auditing company into the Division by August 31, 2018. The Audit Report since the 3rd quarter of 2018 will be granted because of the Auditing company towards the Division by November 30, 2018. The Audit Report since the 4th quarter of 2018 will probably be given by the Auditing Firm towards the Division by February 28, 2019, in addition to Audit Report addressing season 2018 will probably be given because of the Auditing company towards the Division by March 29, 2019.
  5. The businesses each shall receive the prior written approval through the Division about the scope of this review before reviews are initiated . The Audits will be carried out by the Auditing Firm formerly decided by the Division.
  6. absolutely absolutely Nothing in this Consent purchase, such as the modifications created by Quicken Loans described above as well as the re payment established in paragraph 3, will probably be construed being an admission, concession, or contract that either or each associated with Companies neglected to conform to any relevant legislation, guideline, legislation, or regulatory bulletin to that the organizations are subject and that is enforceable by the Division.
  7. The firms each shall establish, implement, keep, and occasionally upgrade running policies and training procedures to ensure all relevant workers involved with the collection and reporting of HMDA information have a very comprehensive knowledge of the policies and procedures known in Paragraph 2 of the Consent Order and when you look at the Policy explanation. Such training shall fundamentally 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 certain that all training that is relevant to workers is tracked and documented.
  8. From the thirtieth (30th) time following the end of each and every calendar quarter after the date for this Consent purchase, starting with the calendar quarter closing June 30, 2018, the firms each shall furnish written progress reports towards the Division, which shall deal with the annotated following: a. A description associated with the kind, content, and types of any actions taken up to deal with each portion of this Consent purchase and the outcome thereof; and b. Written findings ready by each Company explaining management’s and staff persons’ adherence to your policies and procedures referred to in Paragraph 2 for this Consent purchase and in the Policy definition and also to applicable statutes, laws, and guidelines pertaining to the issues which are the topic of this Consent purchase, in addition to a description of every operational modifications implemented during such quarter that are designed to enhance such Company’s conformity symptom in Massachusetts together with 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 Consent purchase from the Commissioner. The Division may terminate this reporting requirement at its discretion upon the request of either Company.
  10. absolutely absolutely Nothing in this Consent purchase shall be construed as allowing the businesses to break any legislation, guideline, legislation, or regulatory bulletin to that the organizations are subject.
  11. Failure of a business to comply with the regards to this Consent purchase shall represent grounds for permit suspension and/or revocation of such Company, or other formal regulatory action against such business pursuant to relevant conditions for the General Laws for the Commonwealth of Massachusetts.
  12. In consideration with this Consent purchase, topic to Paragraphs 10 and 11, the Division agrees to not ever pursue formal measures, in accordance with this matter, to suspend or revoke either Company’s mortgage company permit or even to just simply take any kind of 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 straight away upon the date of their issuance.
  14. The conditions of the Consent purchase shall remain effective and enforceable except towards the level that, and until such time once the Commissioner or even a court of competent jurisdiction modifies, terminates, suspends, or sets apart any provision with this Consent purchase.
  15. The organizations’ liberties and responsibilities under this Consent purchase are split from one another, and shall endure individually in the case, among other possibilities, this one business shall no further be associated with one other or shall stop to become a licensee.
  16. This Consent Order therefore the agreement that is consent the whole papers representing the quality for this matter. There aren’t any other agreements between your Division and either regarding the businesses.

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