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 into the Division’s legislation 209 CMR 54.00 et seq.;

WHEREAS, the Report of Examination (Report) issued pursuant towards the Division’s examination of Quicken Loans as of August 2, 2016 alleged non-compliance that is substantial relevant Massachusetts and federal statues, guidelines, and regulations regulating the conduct of the involved with the company of a home loan loan provider in Massachusetts pertaining to Quicken Loans’ reporting of particular data elements underneath the Residence Mortgage Disclosure Act (HMDA);

WHILE, a study of ORM had been carried out pursuant to General Laws chapter 255E, part 8, as of November 6, 2017, to assess compliance that is ORM’s the regulations relevant to its company;

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 responsibilities under HMDA; and

WHILE, the Division and Quicken Loans now look for to solve by shared agreement the things identified into the Report, as well as the Division and ORM now seek to eliminate by mutual contract similar things arising relating to the examination that is referenced of.

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Consent Order

NOW COME the parties 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 right component with this purchase.
2. In reaction to your Report, Quicken Loans has implemented specific changes to its policies and procedures for collection and reporting of HMDA information, such that it treats consumer that is certain as applications for HMDA-reporting purposes at an early on phase than have been the way it is before the issuance of this 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 provided confidentially to your Division on paper, contemporaneous using this Consent purchase (Policy Description).
3. The businesses shall remit a payment that is aggregate the quantity of 2 hundred and fifty thousand bucks ($250,000). The businesses shall remit re payment in complete within the quantity indicated above within seven (7) times of the execution for this Consent Order, payable into the “Commonwealth of Massachusetts,” because of the performed copy associated with the Consent Order, to your 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 each one of the organizations’ conformity with such policies and procedures with regards to every one of their yearly HMDA data filings for Calendar Years 2017 and 2018, also conformity during each quarter during 2018. The Audit that is first Report addressing Calendar Year 2017 plus the very first and 2nd quarters of 2018, will be released by the Auditing company to your Division by August 31, 2018. The Audit Report since the 3rd quarter of 2018 will be granted because of the Auditing company into the Division by November 30, 2018. The Audit Report within the fourth quarter of 2018 will probably be given because of the Auditing company into the Division by February 28, 2019, additionally the Audit Report addressing twelve months 2018 will be granted by 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 associated with the review before reviews are initiated . The Audits will probably be carried out by the Auditing Firm formerly decided by the Division.
6. Absolutely Nothing in this order that is consent such as the modifications produced by Quicken Loans described above while 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 neglected to conform to any relevant 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 sporadically upgrade running policies and training procedures to ensure all relevant workers associated with the collection and reporting of HMDA data use a understanding that is comprehensive of policies and procedures known in Paragraph 2 for this Consent Order and when you look at the Policy definition. Such training shall always guarantee the proper execution and execution of all of the revised policies and procedures used pursuant to Paragraph 2 with this Consent purchase. Such policies and training procedures should 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 regarding the type, content, and types of any actions taken fully to deal with each element 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 for this order that is consent in the Policy explanation and to relevant statutes, regulations, and guidelines associated with the things which can be the topic of this Consent purchase, along with a description of every functional modifications implemented during such quarter that are designed to enhance such Company’s conformity symptom in Massachusetts additionally the outcomes thereof.
9. The reporting requirement to your Division referenced in Section 8 of the Consent purchase shall remain in place and shall never be amended or rescinded with no prior written modification, termination, or suspension system regarding 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 Nothing in this Consent purchase shall be construed as allowing the businesses to break any law, guideline, legislation, or bulletin that is regulatory that your organizations 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 business, or any other formal action that is regulatory such business pursuant to relevant provisions associated with the General Laws for 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 even to simply simply take every other formal or any other action against either business with regards to the issues included in this Consent purchase.
13. This Order that is consent shall effective instantly upon the date of its issuance.
14. The conditions of the Consent purchase shall remain effective and enforceable except towards the degree that, and until such time since the Commissioner or 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 the case, my sources among other opportunities, any particular one business shall not any longer be associated with one other or shall cease to become a licensee.
16. This Consent Order together with agreement that is consent the whole papers representing the quality with this matter. There aren’t any other agreements involving the Division and either of this businesses.