Consent Order Quicken Loans, Inc. and another Reverse Home Loan, LLC

Consent Order Quicken Loans, Inc. and another Reverse Home Loan, LLC

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

WHILE, 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 into the Division’s legislation 209 CMR 54.00 et seq.;

WHILE, the Report of Examination (Report) given pursuant towards 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 governing the conduct of the involved in the business enterprise of a home loan loan provider in Massachusetts pertaining to Quicken Loans’ reporting of specific information 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 business has interpreted and used law that is such bad faith and for the goal of intentionally avoiding its reporting responsibilities under HMDA; and

WHILE, the Division and Quicken Loans now seek to eliminate by shared contract the things identified within the Report, as well as the Division and ORM now look for to resolve by shared contract comparable things arising relating to the referenced study of ORM.

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Consent Order

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

  1. The recitals set forth above are incorporated and produced 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 stage than have been the situation before the issuance associated with the Report. a description that is detailed of 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 happens to be provided confidentially to your Division written down, 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 firms shall remit payment in complete 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,” utilizing the executed copy regarding the Consent Order, towards the workplace regarding the Commissioner of Banks, 1000 Washington Street, 10th 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 Companies’ conformity with such policies and procedures pertaining to all of their yearly HMDA information filings for Calendar Years 2017 and 2018, in addition to conformity during each quarter during 2018. The Audit that is first Report addressing season 2017 additionally the first and 2nd quarters of 2018, will probably be granted because of the Auditing Firm towards the Division by August 31, 2018. The Audit Report within the quarter that is third of will 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 given because of the Auditing company to your Division by February 28, 2019, plus the Audit Report addressing twelve months 2018 will be granted because of the Auditing company to your Division by March 29, 2019.
  5. The businesses each shall have the prior written approval through the Division about the range for the review before reviews are initiated . The Audits will probably be carried out because of the Auditing Firm formerly decided because of the Division.
  6. Absolutely absolutely Nothing in this order that is consent such as the modifications produced by Quicken Loans described above additionally the payment established in paragraph 3, will be construed being an admission, concession, or contract that either or both associated with the Companies didn’t conform to any applicable legislation, guideline, legislation, or regulatory bulletin to that your organizations are topic and that is enforceable by the Division.
  7. The firms each shall establish, implement, keep, and sporadically upgrade operating policies and training procedures to make sure that all relevant workers involved with the collection and reporting of HMDA information have a very understanding that is comprehensive of policies and procedures described in Paragraph 2 for this Consent Order and in the Policy explanation. Such training shall always make sure the appropriate execution and execution of most revised policies and procedures used pursuant to Paragraph 2 for this order that is consent. Such policies and training procedures should be made to make sure that all training that is relevant 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 for the kind, content, and method of any actions taken up to deal with each element of this Consent purchase and 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 with this order that is consent when you look at the Policy explanation and also to relevant statutes, regulations, and guidelines linked to the things which can be the main topic of this Consent purchase, along with a description of every operational modifications implemented during such quarter that are meant to enhance such Company’s conformity symptom in Massachusetts as well as the outcomes thereof.
  9. 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 applicable 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 Nothing in this Consent Order shall be construed as allowing the firms to break any legislation, guideline, legislation, or regulatory bulletin to that your Companies are topic.
  11. Failure of a business to conform to the regards to this Consent purchase shall represent grounds for license suspension and/or revocation of such business, or any other formal regulatory action against such business pursuant to relevant conditions associated with the General Laws associated with the Commonwealth of Massachusetts.
  12. In consideration with 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 simply just just take just about any formal or other action against either business with regards to the issues included in this Consent purchase.
  13. This Order that is consent shall effective straight away upon the date of its issuance.
  14. The conditions with this Consent purchase shall remain effective and enforceable except to your degree that, and until such time given that Commissioner or even a court of competent jurisdiction modifies, terminates, suspends, or sets apart any supply with this Consent purchase.
  15. The organizations’ legal rights and responsibilities under this Consent purchase are split from one another, and shall endure separately in the big event, among other possibilities, this 1 business shall no further be associated with one other or shall stop to be a licensee.
  16. This Consent Order additionally the Consent contract are the whole papers representing the quality with this matter. There are not any other agreements involving the Division and either of this businesses.

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