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UNITED STATES OF AMERICA
CONSUMER FINANCIAL PROTECTION BUREAU
ADMINISTRATIVE PROCEEDING
File No. 2023-CFPB-0008
In the Matter of:
CONSENT ORDER
Freedom Mortgage Corporation
The Consumer Financial Protection Bureau (Bureau) has reviewed Freedom
Mortgage Corporation’s (Freedom or Respondent, as defined below) acts and
practices for generating Traditional Reta
il mortgage business and has identified
violations of Section 8(a) of the Real Estate Settlement Procedures Act’s
prohibition on giving things of value for referrals of business incident to or part of
a settlement service involving federally related mortgage loans. 12 U.S.C. §
2607(a) (RESPA), and its implementing regulation, Regulation X, 12 C.F.R. part
1024.
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Under §§ 1053 and 1055 of the Consumer Financial Protection Act of 2010
(CFPA), 12 U.S.C. §§ 5563, 5565, the Bureau issues this Consent Order (Consent
Order).
I.
Jurisdiction
1. The Bureau has jurisdiction over this matter under §§ 1053 and 1055 of the
CFPA, 12 U.S.C. §§ 5563 and 5565, and RESPA Section 8, 12 U.S.C. §
2607(d)(4).
II.
Stipulation
2. Respondent has executed a “Stipulation and Consent to the Issuance of a
Consent Order,” dated August 15, 2023 (Stipulation), which is incorporated
by reference and is accepted by the Bureau. By this Stipulation, Respondent
has consented to the issuance of this Consent Order by the Bureau under §§
1053 and 1055 of the CFPA, 12 U.S.C. §§ 5563, 5565, without admitting or
denying any of the findings of fact or conclusions of law,
except that
Respondent admits the facts necessary to establish the Bureau’s jurisdiction
over Respondent and the subject matter of this action.
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III.
Definitions
3. The following definitions apply to this Consent Order:
a. “Board” means the President as of the Effective Date of this Order, any
future President, and any other current or future members of
Respondent’s Board of Directors.
b. “Effective Date” means the date on which the Consent Order is entered
on the administrative docket.
c. “President” means Respondent’s sole owner and operator and any future
owner or operator of Respondent who serves in a similar or equivalent
capacity.
d. “Supervision Director” means the Assistant Director of the Office of
Supervision Policy for the Consumer Financial Protection Bureau, or
their delegate.
e. “Related Consumer Action” means a private action by or on behalf of
one or more consumers or an enforcement action by another
governmental agency brought against Respondent based on substantially
the same facts as described in Section IV of this Consent Order.
f. “Relevant Period” includes from January 1, 2017 to the Effective Date.
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g. “Respondent”
means Freedom Mortgage Corporation and its successors
and assigns.
h. “Traditional Retail” means the mortgage origination market segment
where loan officers attempt to obtain mortgage origination business
directly from real estate brokers and agents.
i. “Traditional Retail Unit” means Freedom’s business unit focused on the
Traditional Retail mortgage market, which was part of Freedom
Mortgage Corporation from the beginning of the Relevant Period until on
or about August 2021, and conducted through Freedom’s former
subsidiary RoundPoint Mortgage Servicing, Inc. (RoundPoint) from on
or about August 2021 until on or about August 2022.
IV.
Bureau Findings and Conclusions
The Bureau finds the following:
4. Respondent is a privately held residential mortgage loan originator and
servicer headquartered in Boca Raton, Florida.
5. Mortgage origination is a consumer financial product or service under the
CFPA. 12 U.S.C. § 5481(15)(A)(i). Respondent is therefore a “covered
person” as that term is defined by 12 U.S.C. § 5481(6).
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6. The origination of a federally related mortgage loan is a “settlement service”
as that term is defined by RESPA. 12 U.S.C. § 2602(3) & 12 C.F.R. §
1024.2(b).
7. The majority of mortgages originated by Freedom’s Traditional Retail Unit
are “federally related mortgage loans” as that term is defined by RESPA. 12
U.S.C. § 2602(1) & 12 C.F.R. § 1024.2(b).
8. Respondent maintained a Traditional Retail Unit from the beginning of the
Relevant Period until August 2021, when Respondent transferred the
Traditional Retail Unit from Freedom to its RoundPoint subsidiary.
9. Respondent’s RoundPoint subsidiary ceased operations in the Traditional
Retail Unit in August 2022, and Respondent no longer has a Traditional
Retail Unit.
Findings and Conclusions as to Respondent
giving subscription services in exchange for mortgage referrals
10. Freedom paid for several subscription services and then gave free access to
real estate agents and brokers. Many of the real estate agents and brokers
who accepted free access to these subscription services made mortgage
referrals to Freedom’s Traditional Retail loan officers. The subscription
services were a thing of value that Freedom gave to the real estate agents
and brokers. For example, Freedom paid thousands of dollars per month for
one of the subscription services—which provided information concerning
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property reports, sales comparables, and foreclosure data—and over 2,000
real estate agents accepted subscriptions through Freedom’s account.
11. Freedom sometimes required real estate agents and brokers to agree to be
paired with a Freedom Traditional Retail Unit loan officer before Freedom
would give them access to its subscription services. The real estate agents
who received free access to these subscription services (including agents at
both Realty Connect and other brokerages) made more than 1,000 mortgage
referrals to Freedom’s Traditional Retail Unit during the Relevant Period, as
part of a pattern, practice, or course of conduct of giving free access to the
subscription services to create, maintain, and strengthen mortgage referral
relationships, in violation of RESPA Section 8(a). See 12 C.F.R. §
1024.14(e).
Findings and Conclusions as to Respondent
hosting and subsidizing events in exchange for mortgage referrals
12. From at least July 1, 2017 to 2022, Freedom’s Traditional Retail Unit also
hosted and subsidized events for certain real estate brokers and agents. For
many of these events, Freedom would pay for the real estate brokers and
agents’ food, beverages, and alcohol. Some of the events also included
entertainment paid for by Freedom.
13. Freedom’s Traditional Retail Unit would also sometimes give free tickets to
sporting events, charity galas, or other events where the real estate agents
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and brokers would have otherwise needed to pay for their own admission,
food, and alcohol.
14. These events were a thing of value that Freedom gave to the real estate
agents and brokers who attended the events. The events frequently cost
Freedom several thousand dollars or more.
15. Freedom targeted these events at new or existing mortgage referral sources.
Freedom also denied requests for event sponsorship from real estate
brokerages that didn’t refer mortgage business to Freedom’s loan officers.
16. Freedom hosted or subsidized the events for real estate brokerages and
agents as part of a pattern, practice, or course of conduct of giving things of
value to create, maintain, and strengthen mortgage referral relationships, in
violation of RESPA Section 8(a). See 12 C.F.R. § 1024.14(e).
Findings and Conclusions as to Respondent
using MSAs to pay for mortgage referrals
17. Freedom’s Traditional Retail Unit also had marketing services agreements
(MSAs) in place with more than 40 real estate brokerages. Under the MSAs,
Freedom made a monthly payment to each respective brokerage. The
payments ranged from a few hundred to several thousand dollars per month.
The total amount Freedom paid under its MSAs during the Relevant Period
was approximately $90,000 per month.
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18. In return for the monthly payment, the agreements called for the real estate
brokerage counterparties to perform certain marketing services for Freedom.
Freedom’s Traditional Retail Unit structured and implemented the MSAs as
another mechanism to pay for mortgage referrals, rather than compensate
real estate brokerages for marketing to consumers.
19. While some of the marketing services that the real estate brokers were
supposed to perform under the MSA were directed to consumers, some of
the MSAs also required the real estate broker to promote Freedom to the
broker’s own agents. For example, certain agreements required the
brokerage to “conduct E-mail marketing campaigns” and “conduct direct
mail marketing campaigns” directed at the broker’s agents, in addition to the
home buying public.
20. Freedom’s Traditional Retail Unit sometimes documented the number of
referrals that had been made when tracking performance under the MSAs.
21. Freedom also encouraged its MSA partners to use a third-party smartphone
app, which Freedom’s Traditional Retail Unit loan officers would share with
the MSA brokerage’s agents. The agents would then share the app with their
clients. The app, as shared with the clients, featured the Freedom loan
officer’s headshot and Freedom logo at the top, and included buttons where
the client could directly contact the Freedom loan officer for assistance.
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22. Many of the real estate agents who received free subscriptions and attended
events that were hosted or subsidized by Freedom also worked at real estate
brokerages that received monthly payments through an MSA.
23. Although Freedom did some joint marketing with real estate brokers to
consumers under the MSAs, Freedom performed most of the actual
marketing services covered under the MSAs. For example, Freedom
maintained a professional design team and licensed software to create
marketing copy, such as co-branded mailers or open house flyers. Freedom
also had a print shop that created the hard copies of co-branded marketing
materials.
24. As explained above, Freedom’s payments made to the real estate brokerages
through MSAs were both structured and implemented to generate mortgage
referrals, rather than compensate the brokerages for any marketing services
they actually performed. Freedom’s payments that it gave to the brokerages
and that the brokerages accepted bore no reasonable relationship to the net
market value of any marketing services the brokerages may have actually
performed or provided. Freedom gave the MSA payments to real estate
brokers as part of a pattern, practice, or course of conduct to create,
maintain, and strengthen mortgage referral relationships in violation of
RESPA Section 8(a). 12 U.S.C. § 2607(a) & 12 C.F.R. § 1024.14(e).
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Findings and Conclusions as to Respondent’s
Violations of CFPA Section 1036
25. Respondent, as explained above in ¶¶ 10-24, gave numerous things of value
to real estate brokers and agents—including monthly MSA payments,
subscription services, and meals, beverages, and entertainment—under an
agreement or understanding to receive referrals of mortgage origination
business for federally related mortgage loans, in violation of RESPA Section
8(a), 12, U.S.C. § 2607(a) and Regulation X, 12 C.F.R. § 1024.14(b), (e).
26. A violation of a Federal consumer financial law is a violation of Section
1036 of the CFPA. 12 U.S.C. § 5536(a)(1)(A). RESPA is a Federal
consumer financial law. 12 U.S.C. §§ 5481(12)(M), (14). Therefore,
Respondent violated Section 1036 of the CFPA.
CONDUCT PROVISIONS
V.
Prohibited Conduct
IT IS ORDERED, under §§ 1053 and 1055 of the CFPA, that:
27. Respondent and its officers, agents, servants, employees, and attorneys, and
all other persons in active concert or participation with them who receive
actual notice of this Consent Order, whether acting directly or indirectly, in
connection with any Traditional Retail business, must not violate Section 8
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of RESPA, 12 U.S.C. § 2607, or its implementing regulation, Regulation X,
12 C.F.R. § 1024.14, and are prohibited from:
a. providing or paying for, or agreeing to provide or pay for
subscription services, food, drink, or entertainment, or giving any
other thing of value, in exchange for referring any person to
Respondent for real estate settlement services;
b. accepting, making, or agreeing to accept or make payments that do
not bear a reasonable relationship to the market value of the goods,
facilities, or services actually provided under an MSA that involves
marketing Respondent’s real estate settlement services-related
business to any person; and
c. giving or accepting any fee, kickback, or thing of value pursuant to
any agreement or understanding, oral or otherwise, that business
incident to or part of a real estate settlement service involving a
federally related mortgage loan shall be referred to any person.
VI.
Compliance Plan
IT IS FURTHER ORDERED that:
28. In the event Respondent intends to resume, create, or acquire Traditional
Retail operations, Respondent must, at least 30 days before resuming
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Traditional Retail operations, submit to the Supervision Director, for review
and non-objection, a comprehensive compliance plan designed to ensure that
Respondent’s Traditional Retail policies and procedures comply with all
applicable laws that the Bureau enforces, including Federal consumer
financial laws, and the terms of this Consent Order (Compliance Plan). The
Compliance Plan must include, at a minimum:
a. detailed steps for addressing each action required by this Consent
Order;
b. a mechanism to ensure that the Board is kept apprised of the status of
compliance actions; and
c. specific timeframes and deadlines for implementation of the steps
described above.
VII.
The Board’s Role
IT IS FURTHER ORDERED that:
29. Respondent’s Board has the ultimate responsibility for ensuring that
Respondent complies with this Consent Order.
30. The Board must review all plans and reports required by this Consent Order,
and any submissions to the Bureau prior to such submission.
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31. One year after the Effective Date, Respondent must submit to the
Supervision Director an accurate written compliance progress report
(Compliance Report) that has been approved by the Board, the accuracy of
which is sworn to under penalty of perjury by Respondent’s Board and
which, at a minimum:
a. Describes the steps that Respondent’s Board have taken to reasonably
assess whether Respondent is complying with each applicable
paragraph and subparagraph of the Order and the Compliance Plan, if
applicable;
b. Describes in detail whether and how Respondent has complied with
each applicable paragraph and subparagraph of the Order and
Compliance Plan, if applicable, including the manner of verification
of such compliance and any corrective actions taken to remedy
potential non-compliance with the applicable requirement, paragraph,
or subparagraph; and
c. attaches a copy of each Order Acknowledgment obtained under
Section X, unless previously submitted to the Bureau.
32. Respondent’s Board must:
a. Authorize whatever actions are necessary for Respondent to assess
whether Respondent is complying with each applicable paragraph and
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subparagraph of the Consent Order and with the Compliance Plan, if
applicable;
b. Authorize whatever actions, including corrective actions, are
necessary for Respondent to fully comply with each applicable
paragraph and subparagraph of the Order and the Compliance Plan, if
applicable;
c. Require timely reporting by management to the Board on the status of
compliance obligations; and
d. Require timely and appropriate corrective action to remedy any
material non-compliance with the directives related to this Section.
MONETARY PROVISIONS
VIII.
Order to Pay Civil Money Penalty
IT IS FURTHER ORDERED that:
33. Under § 1055(c) of the CFPA, 12 U.S.C. § 5565(c), by reason of the
violations of law described in Section IV of this Consent Order, Respondent
must pay a civil money penalty of $1.75 million to the Bureau.
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34. Within 10 days of the Effective Date, Respondent must pay the civil money
penalty by wire transfer to the Bureau or to the Bureau’s agent in
compliance with the Bureau’s wiring instructions.
35. The civil money penalty paid under this Consent Order will be deposited in
the Civil Penalty Fund of the Bureau as required by § 1017(d) of the CFPA,
12 U.S.C. § 5497(d).
36. Respondent, for all purposes, must treat the civil money penalty paid under
this Consent Order as a penalty paid to the government. Regardless of how
the Bureau ultimately uses those funds, Respondent may not:
a. Claim, assert, or apply for a tax deduction, tax credit, or any other tax
benefit for any civil money penalty paid under this Consent Order; or
b. Seek or accept, directly or indirectly, reimbursement or
indemnification from any source, including but not limited to payment
made under any insurance policy, with regard to any civil money
penalty paid under this Consent Order.
37. To preserve the deterrent effect of the civil money penalty in any Related
Consumer Action, Respondent may not argue that Respondent is entitled to,
nor may Respondent benefit by, any offset or reduction of any compensatory
monetary remedies imposed in the Related Consumer Action because of the
civil money penalty paid in this action or because of any payment that the
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Bureau makes from the Civil Penalty Fund. If the court in any Related
Consumer Action offsets or otherwise reduces the amount of compensatory
monetary remedies imposed against Respondent based on the civil money
penalty paid in this action or based on any payment that the Bureau makes
from the Civil Penalty Fund, Respondent must, within 30 days after entry of
a final order granting such offset or reduction, notify the Bureau, and pay the
amount of the offset or reduction to the U.S. Treasury. Such a payment will
not be considered an additional civil money penalty and will not change the
amount of the civil money penalty imposed in this action.
38. In the event of any default on Respondent’s obligations to make payment
under this Consent Order, interest, computed under 28 U.S.C. § 1961, as
amended, will accrue on any outstanding amounts not paid from the date of
default to the date of payment, and will immediately become due and
payable.
39. Respondent must relinquish all dominion, control, and title to the funds paid
to the fullest extent permitted by law and no part of the funds may be
returned to Respondent.
40. Under 31 U.S.C. § 7701, Respondent, unless it already has done so, must
furnish to the Bureau its taxpayer-identification numbers, which may be
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used for purposes of collecting and reporting on any delinquent amount
arising out of this Consent Order.
41. Within 30 days of the entry of a final judgment, consent order, or settlement
in a Related Consumer Action, Respondent must notify the Regional
Director of the final judgment, consent order, or settlement in writing. That
notification must indicate the amount of redress, if any, that Respondent paid
or is required to pay to consumers and describe the consumers or classes of
consumers to whom that redress has been or will be paid.
COMPLIANCE PROVISIONS
IX.
Reporting Requirements
IT IS FURTHER ORDERED that:
42. Respondent must notify the Bureau of any development that may affect
compliance obligations arising under this Consent Order, including but not
limited to a dissolution, assignment, sale, merger, or other action that would
result in the emergence of a successor company; the creation or dissolution
of a subsidiary, parent, or affiliate that engages in any acts or practices
subject to this Consent Order; the filing of any bankruptcy or insolvency
proceeding by or against Respondent; or a change in Respondent’s name or
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address. Respondent must provide this notice, if practicable, at least 30 days
before the development, but in any case no later than 14 days after the
development.
43. Within 7 days of the Effective Date, Respondent must:
a. Designate at least one telephone number and email, physical, and
postal addresses as points of contact that the Bureau may use to
communicate with Respondent;
b. Identify all businesses for which Respondent is the majority owner, or
that Respondent directly or indirectly controls, by all of their names,
telephone numbers, and physical, postal, email, and Internet
addresses; and
c. Describe the activities of each such business, including the products
and services offered, and the means of advertising, marketing, and
sales.
44. Respondent must report any change in the information required to be
submitted under Paragraph 43 at least 30 days before the change or as soon
as practicable after learning about the change, whichever is sooner.
X.
Order Distribution and Acknowledgment
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IT IS FURTHER ORDERED that:
45. Within 7 days of the Effective Date, Respondent must submit to the
Regional Director an acknowledgment of receipt of this Consent Order,
sworn under penalty of perjury.
46. Within 30 days of the Effective Date, Respondent must deliver a copy of this
Consent Order to each of its executive officers and each member of the
Board, as well as to any vice presidents, managers, loan officers, employees,
service providers, or other agents and representatives who have
responsibilities related to the subject matter of the Consent Order.
47. For 5
years from the Effective Date, Respondent must deliver a copy of this
Consent Order to any business entity resulting from any change in structure
referred to in Section IX, any future executive officers and members of the
Board, as well as to any vice presidents, managers, loan officers, employees,
service providers, or other agents and representatives who will have
responsibilities related to the subject matter of the Consent Order before they
assume their responsibilities.
48. Respondent must secure a signed and dated statement acknowledging receipt
of a copy of this Consent Order, ensuring that any electronic signatures
comply with the requirements of the E-Sign Act, 15 U.S.C. § 7001 et seq.,
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within 30 days of delivery, from all persons receiving a copy of this Consent
Order under this Section.
49. Ninety days from the Effective Date, Respondent must submit to the Bureau
a list of all persons and their titles to whom this Consent Order has been
delivered under the Section of this Order titled “Order Distribution and
Acknowledgment” and a copy of all signed and dated statements
acknowledging receipt of this Consent Order under Paragraph 48.
XI.
Recordkeeping
IT IS FURTHER ORDERED that:
50. Respondent must create and retain the following business records associated
with Traditional Retail:
a. all documents and records necessary to demonstrate full compliance
with each provision of this Consent Order and, if applicable, the
Compliance Plan, including all submissions to the Bureau;
b. general ledger accounting records in the format used in the ordinary
course of business, for expenses and revenues directly associated with
Traditional Retail mortgage origination;
c. all emails, instructions, and other documents related to any
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subscription service paid for or subsidized in whole or in part by
Respondent and given to a real estate settlement service provider;
d. all emails, instructions, and other documents related to any event
hosted by or paid in full or in part by Respondent and involving things
of value given to a real estate settlement service provider;
e. all consumer complaints and refund requests associated with
Traditional Retail (whether received directly or indirectly, such as
through a third party), and any responses to those complaints or
requests;
f. records showing, for each employee providing Traditional Retail
mortgage origination services, that person’s name, telephone number,
email, physical, and postal address, job title or position, dates of
service, and, if applicable, the reason for termination; and
g. records showing, for each service provider providing Traditional
Retail mortgage origination services (excluding independent mortgage
brokers that partner with Respondent’s wholesale channel), the name
of a point of contact as well as that person’s telephone number, email,
physical, and postal address, job title or position, dates of service, and,
if applicable, the reason for termination.
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51. All documents and records must be maintained in their original electronic
format. Data should be centralized, and maintained in such a way that
access, retrieval, auditing and production are not hindered.
52. Respondent must make the documents identified in Paragraph 50 available
to the Bureau upon the Bureau’s request.
XII.
Notices
IT IS FURTHER ORDERED that:
53. Unless otherwise directed in writing by the Bureau, Respondent must
provide all submissions, requests, communications, or other documents
relating to this Consent Order in writing, with the subject line, “In re
Freedom Mortgage Corp., File No. 2023-CFPB-0008,” and send them to
the following email: [email protected] addressed as
follows:
ATTN: Supervision Director,
Consumer Financial Protection Bureau
Office of Supervision Policy
XIII.
Compliance Monitoring
IT IS FURTHER ORDERED that:
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54. Within 14 days of receipt of a written request from the Bureau, Respondent
must submit additional Compliance Reports or other requested information,
which must be made under penalty of perjury; provide sworn testimony; or
produce documents.
55. Respondent must permit Bureau representatives to interview any employee
or other person affiliated with Respondent who has agreed to such an
interview regarding: (a) this matter; (b) anything related to or associated
with the conduct described in Section IV; or (c) compliance with the
Consent Order. The person interviewed may have counsel present.
56. Nothing in this Consent Order will limit the Bureau’s lawful use of civil
investigative demands under 12 C.F.R. § 1080.6 or other compulsory
process.
XIV.
Modifications to Non-Material Requirements
IT IS FURTHER ORDERED that:
57. Respondent may seek a modification to non-material requirements of this
Consent Order (e.g., reasonable extensions of time and changes to reporting
requirements) by submitting a written request to the Supervision Director.
58. The Supervision Director may, in their discretion, modify any non-material
requirements of this Consent Order (e.g., reasonable extensions of time and
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changes to reporting requirements) if they determine good cause justifies the
modification. Any such modification by the Supervision Director must be in
writing.
ADMINISTRATIVE PROVISIONS
XV.
IT IS FURTHER ORDERED that:
59. The provisions of this Consent Order do not bar, estop, or otherwise prevent
the Bureau from taking any other action against Respondent, except as
described in Paragraph 60, below. Further, for the avoidance of doubt, the
provisions of this Consent Order do not bar, estop, or otherwise prevent any
other person or governmental agency from taking any action against
Respondent.
60. The Bureau releases and discharges Respondent from all potential liability
for law violations that the Bureau has or might have asserted based on the
practices described in Section IV of this Consent Order, to the extent such
practices occurred before the Effective Date and the Bureau knows about
them as of the Effective Date. The Bureau may use the practices described in
this Consent Order in future enforcement actions against Respondent and its
affiliates, including, without limitation, to establish a pattern or practice of
violations or the continuation of a pattern or practice of violations or to
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calculate the amount of any penalty. This release does not preclude or affect
any right of the Bureau to determine and ensure compliance with the
Consent Order, or to seek penalties for any violations of the Consent Order.
61. This Consent Order is intended to be, and will be construed as, a final
Consent Order issued under § 1053 of the CFPA, 12 U.S.C. § 5563, and
expressly does not form, and may not be construed to form, a contract
binding the Bureau or the United States.
62. This Consent Order will terminate on the later of 5 years from the Effective
Date or 5 years from the most recent date that the Bureau initiates an action
alleging any violation of the Consent Order by Respondent, if such action is
initiated within 5 years of the Effective Date. If such action is dismissed or
the relevant adjudicative body rules that Respondent did not violate any
provision of the Consent Order, and the dismissal or ruling is either not
appealed or upheld on appeal, then the Consent Order will terminate as
though the action had never been filed. The Consent Order will remain
effective and enforceable until such time, except to the extent that any
provisions of this Consent Order have been amended, suspended, waived, or
terminated in writing by the Bureau or its designated agent.
63. Calculation of time limitations will run from the Effective Date and be based
on calendar days, unless otherwise noted.
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64. Should Respondent seek to transfer or assign all or part of its operations that
are subject to this Consent Order, Respondent must, as a condition of sale,
obtain the written agreement of the transferee or assignee to comply with all
applicable provisions of this Consent Order.
65. The provisions of this Consent Order will be enforceable by the Bureau. For
any violation of this Consent Order, the Bureau may impose the maximum
amount of civil money penalties allowed under §1055(c) of the CFPA, 12
U.S.C. § 5565(c). In connection with any attempt by the Bureau to enforce
this Consent Order in federal district court, the Bureau may serve
Respondent wherever Respondent may be found and Respondent may not
contest that court’s personal jurisdiction over Respondent.
66. This Consent Order and the accompanying Stipulation contain the complete
agreement between the parties. The parties have made no promises,
representations, or warranties other than what is contained in this Consent
Order and the accompanying Stipulation. This Consent Order and the
accompanying Stipulation supersede any prior oral or written
communications, discussions, or understandings.
67. Nothing in this Consent Order or the accompanying Stipulation may be
construed as allowing Respondent, its Board, executives, officers, or
employees to violate any law, rule, or regulation.
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IT IS SO ORDERED, this 17th day of August, 2023.
____________________________
Rohit Chopra
Director
Consumer Financial Protection Bureau
t
f
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