Question Description
On August 12, 2014, the Consumer Financial Protection Bureau (CFPB) took action against Amerisave
Mark Smith had been in the mortgage business for over seven years before finally opening his own
companyMark Smith Mortgage (MCM) as a CRMLA-licensed mortgage lender. The main focus of his
business was to originate and fund federally related residential mortgage loans.
Mark was careful to follow all of the rules and regulations required under the California Financial Code for
CRMLA-licensed lenders. For example, MCM conspicuously displayed the licenses of the sponsored
mortgage loan originators at the authorized place of business. In addition, he made sure to supervise the
lending activities of every mortgage loan originator that MCM sponsored. To meet this goal, Mark
monitored the phone calls of his sponsored MLOs, reviewed their paperwork for accuracy, and checked
all advertising to be sure that there were no misleading statements being made to borrowers.
Olive, the office manager, was in charge of handling administrative and accounting tasks. She set up a
system to keep MCMs books, accounts, and records in compliance with the DBO Commissioners rules
and regulations.
The residential real estate market finally improved and business was booming. Mark was busy hiring and
training new MLOs, both CRMLA mortgage loan originators and licensed California real estate agents
with the MLO license endorsement. In addition to her current duties, Mark asked Olive to monitor the
licenses of all the sponsored MLOs to be sure the licenses were current and in compliance with the
NMLS. With over 200 sponsored MLOs, Olive was having difficulty keeping up with all of her
responsibilities, so she set up a system to track the MLO licenses.
Imagine his shock when during a regulatory examination conducted by the DBO Commissioner, Mark was
informed that some of his sponsored MLOs had inactive licenses. In fact, one person who was a licensed
real estate broker with the MLO endorsement had not renewed her real estate license.
What was MSMs violation and what enforcement action(s) could the DBO Commissioner take against
Mike Smith Mortgage?
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