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, a 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) issued pursuant to your Division’s study of Quicken Loans as of August 2, 2016 alleged non-compliance that is substantial relevant Massachusetts and federal statues, guidelines, and laws regulating the conduct of these involved in the business enterprise of a home loan loan provider in Massachusetts with regards to Quicken Loans’ reporting of particular information elements underneath the Residence Mortgage Disclosure Act (HMDA);

WHILE, an study of ORM had been carried out pursuant to General Laws chapter 255E, section 8, at the time of November 6, 2017, to assess compliance that is ORM’s 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 or for the objective of deliberately avoiding its reporting responsibilities under HMDA; and

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

Dining dining Table of articles

Consent Order

NOW COME the events when you look at the above-captioned matter, the Division together with businesses, and stipulate and agree as follows:

1. The recitals set forth above are incorporated and produced component for this purchase.
2. In reaction 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 particular customer demands as applications for HMDA-reporting purposes at a youthful phase than have been the truth ahead of the issuance associated with Report. a detail by detail description of quicken 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 is supplied confidentially into the Division written down, contemporaneous using this Consent purchase (Policy Description).
3. The firms shall remit an aggregate repayment in the total amount of 2 hundred and fifty thousand bucks ($250,000). The businesses shall remit re payment in complete into the quantity indicated above within seven (7) times of the execution for this Consent Order, payable towards the “Commonwealth of Massachusetts,” because of the performed copy associated with Consent Order, into the workplace associated with 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 all the ongoing companies’ conformity with such policies and procedures pertaining to all of their annual HMDA information filings for Calendar Years 2017 and 2018, along with conformity during each quarter during 2018. The very first Audit Report, addressing season 2017 in addition to very very first and 2nd quarters of 2018, shall be given because of the Auditing company into the Division by August 31, 2018. The Audit Report since the 3rd quarter of 2018 will be granted because of the Auditing company towards the Division by November 30, 2018. The Audit Report within the 4th quarter of 2018 will probably be given because of the Auditing company towards the Division by February 28, 2019, therefore the Audit Report addressing season 2018 will be released because of the Auditing company towards the Division by March 29, 2019.
5. The businesses each shall have the prior written approval through the Division concerning the range for the review before reviews are initiated . The Audits will probably be conducted by the Auditing Firm formerly decided by the Division.
6. Absolutely Nothing in this order that is consent such as the modifications created by Quicken Loans described above additionally the re re payment established in paragraph 3, will probably be construed as an admission, concession, or contract that either or each regarding the Companies neglected to conform to any relevant legislation, guideline, legislation, or regulatory bulletin to that the businesses are topic and that is enforceable by the Division.
7. The businesses each shall establish, implement, keep, and occasionally upgrade operating policies and training procedures to make sure that all relevant workers tangled up in the collection and reporting of HMDA information use a comprehensive knowledge of the policies and procedures described in Paragraph 2 for this Consent Order and when you look at the Policy explanation continue reading this. Such training shall fundamentally make sure the appropriate execution and execution of most revised policies and procedures used pursuant to Paragraph 2 for this Consent Order. Such policies and training procedures must certanly be built to make sure all training that is relevant to workers is tracked and documented.
8. In the thirtieth (30th) time following the end of every calendar quarter after the date with this Consent purchase, starting with the calendar quarter closing June 30, 2018, the businesses each shall furnish written progress reports to your Division, which shall deal with the annotated following: a. A description associated with the type, content, and method of any actions taken fully to deal with each part 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 with this order that is consent when you look at the Policy explanation and also to relevant statutes, laws, and rules associated with the issues which are the topic of this Consent purchase, also a description of any functional modifications implemented during such quarter that are meant to enhance such Company’s conformity symptom in Massachusetts and also the outcomes thereof.
9. The reporting requirement to your Division referenced in Section 8 with this Consent purchase shall remain in place and shall never be amended or rescinded with no prior written modification, termination, or suspension system associated with the 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 absolutely absolutely Nothing in this Consent purchase shall be construed as permitting the businesses to break any legislation, guideline, regulation, 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 license suspension and/or revocation of such business, or any other formal action that is regulatory such business pursuant to relevant conditions for the General Laws regarding the Commonwealth of Massachusetts.
12. 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 to just just take some other formal or other action against either business with respect to the issues included in this Consent purchase.
13. This Order that is consent shall effective immediately upon the date of its issuance.
14. The conditions of the Consent purchase shall remain effective and enforceable except to your degree that, and until such time because the 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 order that is consent split from one another, and shall endure individually in case, among other opportunities, this 1 business shall no further be associated with one other or shall stop to become a licensee.
16. This Consent Order together with Consent contract are the whole papers representing the quality of the matter. There aren’t any other agreements involving the Division and either of this businesses.