Consent Order Quicken Loans, Inc. plus one Reverse Home Loan, LLC
Consent Order Quicken Loans, Inc. plus one Reverse Home Loan, LLC
Date: 04/20/2018 Organization: Division of Banks Docket Number: 2017-005 Location: Detriot, Michigan and north park, Ca
WHEREAS, an 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 within the Division’s legislation 209 CMR 54.00 et seq.;
WHILE, the Report of Examination (Report) given pursuant into the 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 these involved in the company of home financing loan provider in Massachusetts pertaining to Quicken Loans' reporting of particular data elements beneath the Residence Mortgage Disclosure Act (HMDA);
WHILE, a study of ORM had been carried out pursuant to General Laws chapter 255E, part 8, at the time of November 6, 2017, to assess ORM’s compliance with the legal guidelines relevant to its company;
WHILE, the Division has made no discovering that either Company has interpreted and used law that is such bad faith or even for the objective 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, in addition to Division and ORM now look for to solve by shared contract comparable things arising associated with the examination that is referenced of.
Table of Contents
Consent Order
NOW COME the events within the above-captioned matter, the Division in addition to businesses, and stipulate and agree as follows:
The recitals set forth above are incorporated and produced right component with this purchase.
As a result 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 needs as applications for HMDA-reporting purposes at a youthful phase than was in fact the situation before the issuance for the Report. a description that is detailed of Loans’ policies and procedures, changed in response into the Report, and of ORM’s parallel policies and procedures for collection and reporting of HMDA information was provided confidentially towards the Division on paper, contemporaneous with this specific Consent purchase (Policy Description).
The businesses shall remit a payment that is aggregate the total amount of 2 hundred and fifty thousand bucks ($250,000). The Companies shall remit payment in complete within the quantity suggested above within seven (7) times of the execution of this Consent Order, payable to your “Commonwealth of Massachusetts,†because of the performed copy associated with the Consent Order, into the workplace for the Commissioner of Banks, 1000 Washington Street, tenth Floor, Boston, Massachusetts 02118.
Within thirty (30) times of the effective date of the Consent Order, the businesses each shall engage a completely independent auditing firm (Auditing Firm) to conduct an audit breakdown of the continued utilization of the policies and procedures outlined in Paragraph 2 for this Consent Order and into the Policy definition 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 with regards to every one of their yearly HMDA information filings for Calendar Years 2017 and 2018, also conformity during each quarter during 2018. The very first Audit Report, addressing season 2017 while the very first and 2nd quarters of 2018, will probably be given by the Auditing company towards the Division by August 31, 2018. The Audit Report covering the 3rd quarter of 2018 will be released because of the Auditing company towards the Division by November 30, 2018. The Audit Report within the 4th quarter of 2018 will be given by the Auditing company to your Division by February 28, 2019, together with Audit Report addressing twelve months 2018 will be granted by the Auditing company into the Division by March 29, 2019.
The companies each shall prior obtain the written approval through the Division about the range associated with review before reviews are initiated . The Audits will be carried out by the Auditing Firm formerly decided by the Division.
Absolutely absolutely Nothing in this order that is consent such as the modifications produced by Quicken Loans described above as well as the payment established in paragraph 3, will be construed being an admission, concession, or contract that either or both regarding the Companies neglected to conform to any relevant legislation, guideline, legislation, or regulatory bulletin to that your businesses are topic and that is enforceable by the Division.
The firms each shall establish, implement, keep, and occasionally upgrade running policies and training procedures to make sure that all relevant workers associated with the collection and reporting of HMDA information have a very understanding that is comprehensive of policies and procedures described in Paragraph 2 of the Consent Order and into the Policy explanation. Such training shall necessarily make sure the appropriate execution and execution of all of the 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 relevant training supplied to workers is tracked and documented.
Regarding the thirtieth (30th) time following the end of every calendar quarter after the date for this Consent purchase, starting with the calendar quarter closing June 30, 2018, the businesses each shall furnish written progress reports into the Division, which shall deal with the annotated following: a. A description of this type, content, and method of any actions taken up to address each part of this Consent purchase and the outcome thereof; and b. Penned findings ready by each Company describing management’s and staff persons’ adherence to your policies and procedures referred to in Paragraph 2 with this Consent purchase and in the Policy explanation and also to relevant statutes, laws, and guidelines associated with the issues which can be the main topic of payday loans Greater London this Consent purchase, also a description of every functional modifications implemented during such quarter that are meant to enhance such Company’s conformity condition in Massachusetts plus the outcomes thereof.
The reporting requirement to your Division referenced in Section 8 of the Consent purchase shall remain in place and shall never be amended or rescinded with no prior written modification, termination, or suspension system of this relevant supply for this Consent Order from the Commissioner. Upon the demand of either business, the Division may end this reporting requirement at its discernment.
absolutely Nothing in this Consent purchase shall be construed as allowing the businesses to break any legislation, rule, legislation, or bulletin that is regulatory that the businesses are topic.
Failure of an organization to adhere to the regards to this Consent purchase shall represent grounds for license suspension and/or revocation of such Company, or any other formal regulatory action against such Company pursuant to relevant conditions associated with the General Laws of this Commonwealth of Massachusetts.
In consideration with this Consent Order, topic to Paragraphs 10 and 11, the Division agrees not to ever pursue formal measures, in accordance with this matter, to suspend or revoke either Company’s mortgage company permit or even just simply take virtually any formal or any other action against either Company with regards to the issues included in this Consent purchase.
This Consent purchase shall be effective instantly upon the date of their issuance.
The conditions of the Consent purchase shall remain effective and enforceable except towards the level 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 Consent Order.
The Companies’ liberties and responsibilities under this order that is consent split from one another, and shall endure individually in the case, among other possibilities, any particular one business shall not any longer be associated with one other or shall cease to be a licensee.
This Consent Order therefore the Consent contract are the entire documents representing the quality of the matter. There are not any other agreements involving the Division and either of this businesses.