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 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.;

WHEREAS, 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 with the business enterprise of home financing loan provider in Massachusetts with regards to Quicken Loans’ reporting of particular information elements beneath the Residence Mortgage Disclosure Act (HMDA);

WHEREAS, 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 deliberately avoiding its reporting responsibilities under HMDA; and

WHILE, the Division and Quicken Loans now look for to solve by shared contract the things identified when you look at the Report, and also the Division and ORM now look for to eliminate by shared agreement comparable issues arising associated with the referenced examination of ORM.

Dining dining Table of Contents

Consent Order

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

  1. The recitals set forth above are incorporated and made a right 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, so that it treats consumer that is certain as applications for HMDA-reporting purposes at an early on phase than was indeed the situation ahead of the issuance of this Report. a description that is detailed of Loans’ policies and procedures, changed in response into the Report, and of ORM’s parallel policies and procedures for collection and reporting of HMDA information is supplied confidentially to your Division on paper, contemporaneous with this particular Consent purchase (Policy Description).
  3. The firms shall remit a payment that is aggregate the quantity of 2 hundred and fifty thousand bucks ($250,000). The firms shall remit re payment in complete into the amount suggested above within seven (7) times of the execution of the Consent Order, payable to your “Commonwealth of Massachusetts,” because of the performed copy associated with Consent Order, towards the 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 all the organizations’ compliance with such policies and procedures with regards to all of their yearly HMDA information filings for Calendar Years 2017 and 2018, also conformity during each quarter during 2018. The first Audit Report, addressing 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 3rd quarter of 2018 will be granted because of the Auditing Firm into the Division by November 30, 2018. The Audit Report within the quarter that is fourth of will probably be released by the Auditing company into the Division by February 28, 2019, additionally the Audit Report addressing twelve months 2018 will be given because of the Auditing company to your Division by March 29, 2019.
  5. The companies each shall prior obtain the written approval through the Division concerning the range regarding the review before reviews are initiated . The Audits will be carried out by the Auditing Firm formerly decided by the Division.
  6. Absolutely absolutely absolutely Nothing in this Consent purchase, such as the modifications created by Quicken Loans described above plus the re re payment established in paragraph 3, will be construed as an admission, concession, or contract that either or both associated with the Companies did not 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 sporadically upgrade running policies and training procedures to make sure that all applicable workers tangled up in the collection and reporting of HMDA information have a very understanding that is comprehensive of policies and procedures described in Paragraph 2 of the Consent Order and into the Policy Description. Such training shall always make sure the appropriate execution and execution of most revised policies and procedures used pursuant to Paragraph 2 with this Consent purchase. Such policies and training procedures must certanly be made to make sure all appropriate training supplied 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 regarding the kind, content, and method of any actions taken up to deal with each portion of this Consent purchase and 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 Consent purchase and in the Policy explanation and also to relevant statutes, laws, and guidelines linked to the issues that are the main topic of this Consent purchase, in addition to a description of every functional changes implemented during such quarter that are meant to enhance such Company’s compliance condition in Massachusetts in addition to outcomes thereof.
  9. The reporting requirement to your Division referenced in Section 8 of the Consent purchase shall remain in place and shall not 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. Nothing in this Consent purchase shall be construed as allowing the firms to break any legislation, guideline, legislation, or bulletin that is regulatory that your organizations are topic.
  11. Failure of a business to conform to 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 regarding the General Laws regarding 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 to just just take some other formal or any other action against either business with regards to the issues included in this order that is consent.
  13. This Consent purchase shall be effective straight away upon the date of their issuance.
  14. The provisions of the Consent purchase shall remain effective and enforceable except to your degree that, and until such time because the Commissioner or 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 Consent Order are split from one another, and shall endure individually in the case, among other opportunities, any particular one business shall not any longer be associated with one other or shall stop to become a licensee.
  16. This Consent Order together with agreement that is consent the entire papers representing the quality of the matter. There aren’t any other agreements amongst the Division and either of the organizations.