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 quantity: 2017-005
Location: Detriot, Michigan and hillcrest, California

WHEREAS, 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 into 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 substantial non-compliance with relevant Massachusetts and federal statues, rules, and laws regulating the conduct of the engaged in business of a home loan loan provider in Massachusetts pertaining to Quicken Loans’ reporting of particular 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 such legislation in bad faith and for the goal of deliberately avoiding its reporting responsibilities under HMDA; and

WHILE, the Division and Quicken Loans now look for to eliminate by mutual agreement the things identified within the Report, and also the Division and ORM now look for to solve by shared contract comparable things arising regarding the the examination that is referenced of.

Table of articles

Consent Order

NOW COME the events within the above-captioned matter, 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 specific customer needs as applications for HMDA-reporting purposes at an early on phase than have been the outcome ahead of the issuance associated with Report. a description that is detailed of Loans’ policies and procedures, changed in response into the Report, as well as ORM’s parallel policies and procedures for collection and reporting of HMDA information happens to be supplied confidentially to your Division on paper, contemporaneous using this Consent purchase (Policy Description).
  3. The firms shall remit a payment that is aggregate the actual quantity of 2 hundred and fifty thousand bucks ($250,000). The firms shall remit re payment in full within the quantity suggested above within seven (7) times of the execution for this Consent Order, payable into the “Commonwealth of Massachusetts,” utilizing the performed copy regarding the Consent Order, to your workplace for the 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 ongoing companies’ compliance with such policies and procedures with regards to every one 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 covering season 2017 plus the very first and 2nd quarters of 2018, will be given by the Auditing company towards the Division by August 31, 2018. The Audit Report since the quarter that is third of will be granted because of the Auditing company into the Division by November 30, 2018. The Audit Report since the quarter that is fourth of will be released because of the Auditing company to your Division by February 28, 2019, additionally the Audit Report addressing twelve months 2018 will probably be given because of the Auditing company into the Division by March 29, 2019.
  5. The organizations each shall have the prior written approval through the Division about the range associated with audit before reviews are initiated . The Audits will be carried out because of the Auditing Firm previously agreed upon because of the Division.
  6. Nothing in this order that is consent such as the modifications produced by Quicken Loans described above plus the re re payment established in paragraph 3, will probably be construed as an admission, concession, or contract that either or each associated with the Companies did not conform to any relevant legislation, guideline, legislation, or regulatory bulletin to that the organizations are topic and that is enforceable because of the Division.
  7. The businesses 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 use a comprehensive knowledge of the policies and procedures described in Paragraph 2 of the Consent Order and when you look at the Policy Description. Such training shall always guarantee the appropriate implementation and execution of most revised policies and procedures used pursuant to Paragraph 2 with this order that is consent. Such policies and training procedures needs to be built to make sure all appropriate training supplied to workers is tracked and documented.
  8. In the thirtieth (30th) time following the end of every calendar quarter following a date with 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 immediate following: a. A description regarding the type, content, and types of any actions taken fully to deal with each portion of this order that is consent 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 of this order that is consent in the Policy explanation and also to relevant statutes, laws, and rules linked to the issues which are the main topic of this Consent purchase, along with a description of any functional modifications implemented during such quarter that are meant to enhance such Company’s conformity condition in Massachusetts in addition to results thereof.
  9. The reporting requirement to your Division referenced in Section 8 for this Consent purchase shall remain in place and shall not be amended or rescinded with no prior written modification, termination, or suspension associated with the relevant provision with this order that is consent the Commissioner. Upon the demand of either business, the Division may end this reporting requirement at its discretion.
  10. Absolutely 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 the organizations are topic.
  11. Failure of an organization to comply with the regards to this Consent purchase shall represent grounds for permit suspension and/or revocation of such business, or other formal action that is regulatory such business pursuant to relevant conditions of this General Laws associated with Commonwealth of Massachusetts.
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  13. 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 license or even simply simply take every other formal or any other action against either business with regards to the issues included in this Consent purchase.
  14. This Consent purchase shall become effective straight away upon the date of its issuance.
  15. The conditions with this Consent purchase shall remain effective and enforceable except towards the degree that, and until such time whilst the Commissioner or a court of competent jurisdiction modifies, terminates, suspends, or sets apart any supply of this order that is consent.
  16. The organizations’ legal rights and obligations under this Consent purchase are split from one another, and shall endure individually in the function, among other opportunities, this 1 business shall no further be associated with one other or shall stop to become a licensee.
  17. This Consent Order together with agreement that is consent the whole papers representing the quality of the matter. There are no other agreements involving the Division and either of this organizations.

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