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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 San Diego, Ca

WHILE, an 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 when you look at 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, rules, and laws regulating the conduct of the involved in the company of home financing lender in Massachusetts pertaining to Quicken Loans’ reporting of specific information elements beneath the Residence Mortgage Disclosure Act (HMDA);

WHILE, an study of ORM had been 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 applicable to its company;

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

WHILE, the Division and Quicken Loans now look for to eliminate by shared contract the things identified into the Report, in addition to Division and ORM now look for to solve by mutual contract comparable issues arising associated with the referenced examination of ORM.

Dining Table of articles

Consent Order

NOW COME the events when you look at the above-captioned matter, the Division in addition to organizations, and stipulate and agree as follows:

  1. The recitals set forth above are incorporated and produced right component for this Order.
  2. As a result into the Report, Quicken Loans has implemented specific modifications to its policies and procedures for collection and reporting of HMDA data, such that it treats particular consumer needs as applications for HMDA-reporting purposes at a youthful stage than have been the outcome before the issuance for the Report. a description that is detailed of Loans’ policies and procedures, changed in response towards the Report, and of ORM’s parallel policies and procedures for collection and reporting of HMDA information happens to be supplied confidentially towards the Division written down, contemporaneous with this specific Consent purchase (Policy Description).
  3. The businesses shall remit a payment that is aggregate the actual quantity of 2 hundred and fifty thousand bucks ($250,000). The businesses shall remit re re payment in complete within the amount suggested above within seven (7) days of the execution for this Consent Order, payable to your “Commonwealth of Massachusetts,” utilizing the performed copy for the Consent Order, to your workplace associated with the 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 overview of 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 with regards to all of their annual 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 together with very very first and 2nd quarters of 2018, will probably be released because of the Auditing company towards the Division by August 31, 2018. The Audit Report since the quarter that is third of will probably be granted by the Auditing company towards the Division by November 30, 2018. The Audit Report within the quarter that is fourth of will be released by the Auditing company into the Division by February 28, 2019, in addition to Audit Report addressing twelve months 2018 will probably be given because of online payday loans Essex no credit check the Auditing company towards the Division by March 29, 2019.
  5. The businesses each shall receive the prior written approval from the Division about the scope of this review before reviews are initiated . The Audits will probably be carried out because of the Auditing Firm formerly decided by the Division.
  6. absolutely absolutely Nothing in this order that is consent such as the modifications created by Quicken Loans described above plus the re re payment set forth in paragraph 3, will probably be construed as an admission, concession, or contract that either or both associated with Companies neglected to conform to any relevant legislation, guideline, legislation, or regulatory bulletin to that your businesses are subject and that is enforceable by the Division.
  7. The firms each shall establish, implement, keep, and sporadically upgrade running policies and training procedures to ensure all relevant workers tangled up in the collection and reporting of HMDA information have a very understanding that is comprehensive of policies and procedures known in Paragraph 2 for this Consent Order and when you look at the Policy explanation. Such training shall always guarantee the appropriate execution and execution of most revised policies and procedures used pursuant to Paragraph 2 with this order that is consent. Such policies and training procedures must certanly be built 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 associated with kind, content, and method of any actions taken up to deal with each area of this Consent purchase and the outcomes thereof; and b. Penned findings prepared 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 pertaining to the things which are the main topic of this Consent purchase, along with a description of every functional modifications implemented during such quarter that are meant to enhance such Company’s conformity condition in Massachusetts together with results thereof.
  9. The reporting requirement to your 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 for the 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 discernment.
  10. Absolutely 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 your businesses are topic.
  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 business, or any other formal action that is regulatory such Company pursuant to relevant conditions of this General Laws regarding 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 just just just take virtually any formal or any other action against either Company with regards to the issues included in this order that is consent.
  13. This Order that is consent shall effective straight away upon the date of the issuance.
  14. The provisions with this 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 order that is consent.
  15. The organizations’ legal rights and responsibilities under this order that is consent split from one another, and shall endure separately in case, among other opportunities, this 1 business shall no further be associated with one other or shall stop to be a licensee.
  16. This Consent Order together with Consent contract are the entire papers representing the quality with this matter. There aren’t any other agreements involving the Division and either of this businesses.

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