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 north park, 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 within 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 applicable Massachusetts and federal statues, guidelines, and laws governing the conduct of these involved in the business enterprise of a home loan loan provider in Massachusetts with regards to Quicken Loans’ reporting of specific information elements underneath the Home 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 compliance that is ORM’s the legal guidelines applicable to its business;

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

WHILE, the Division and Quicken Loans now look for to eliminate by shared contract the issues identified within the Report, while 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 into the above-captioned matter, the Division as well as the organizations, and stipulate and agree as follows:

  1. The recitals set forth above are incorporated and produced component with this purchase.
  2. As a result towards the Report, Quicken Loans has implemented certain modifications to its policies and procedures for collection and reporting of HMDA data, such that it treats particular customer demands as applications for HMDA-reporting purposes at a youthful stage than was in fact the scenario before the issuance regarding the Report. a detail by detail description of quicken Loans’ policies and procedures, changed in response towards 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 written down, 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 complete when you look at the quantity suggested above within seven (7) times of the execution of the Consent Order, payable to your “Commonwealth of Massachusetts,” utilizing the executed copy regarding the Consent Order, towards the Office associated with Commissioner of Banks, 1000 Washington Street, tenth Floor, Boston, Massachusetts 02118.
  4. Within thirty (30) days of the effective date of the Consent Order, the firms each shall engage a completely independent 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 ongoing companies’ compliance with such policies and procedures payday loans Gloucestershire 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 very first Audit Report, addressing season 2017 together with very very first and 2nd quarters of 2018, will probably be given because of the Auditing company towards the Division by August 31, 2018. The Audit Report within the 3rd quarter of 2018 will be released because of the Auditing company into the Division by November 30, 2018. The Audit Report within the quarter that is fourth of will probably be given by the Auditing company towards the Division by February 28, 2019, additionally the Audit Report addressing twelve months 2018 will be released by the Auditing Firm towards the Division by March 29, 2019.
  5. The companies each shall prior obtain the written approval through the Division concerning the range of this review before reviews are initiated . The Audits will be carried out because of the Auditing Firm formerly decided by the Division.
  6. Absolutely absolutely absolutely Nothing in this order that is consent including 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 the Companies did not conform to any applicable legislation, guideline, legislation, or regulatory bulletin to that the businesses are topic and that is enforceable because of the Division.
  7. The firms each shall establish, implement, keep, and occasionally upgrade operating policies and training procedures to ensure all relevant workers tangled up in the collection and reporting of HMDA information possess a comprehensive knowledge of the policies and procedures described in Paragraph 2 of 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 with this order that is consent. Such policies and training procedures must certanly be built to make sure that all appropriate training supplied to employees 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 regarding the kind, content, and method of any actions taken fully to deal with each area of this order that is consent the outcome 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 for this order that is consent when you look at the Policy definition and also to applicable statutes, laws, and guidelines associated with the things which can be the topic of this Consent purchase, in addition to a description of every functional modifications implemented during such quarter that are designed to enhance such Company’s conformity condition in Massachusetts while the outcomes 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 of this 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 Nothing in this Consent purchase shall be construed as allowing the firms to break any legislation, guideline, legislation, or regulatory bulletin to that your businesses are topic.
  11. Failure of an organization to adhere to the regards to this Consent purchase shall represent grounds for permit suspension and/or revocation of such Company, or other formal action that is regulatory such Company pursuant to relevant conditions regarding the General Laws for the Commonwealth of Massachusetts.
  12. In consideration with this Consent purchase, 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 to just take any kind of formal or any other action against either business 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 conditions with this Consent purchase shall remain effective and enforceable except towards the degree that, and until such time because the Commissioner or perhaps a court of competent jurisdiction modifies, terminates, suspends, or sets apart any supply with this Consent purchase.
  15. The organizations’ liberties and responsibilities under this Consent Order are split from one another, and shall endure individually in the case, among other opportunities, this 1 business shall not any longer be associated with one other or shall stop to be a licensee.
  16. This Consent Order therefore the Consent contract are the whole documents representing the quality with this matter. There are not any other agreements involving the Division and either regarding the organizations.