Mortgage Master, Inc.
Documents in this case
- Consent order · · 14 p.
- Stipulation · · 6 p.
Case summary
The Bureau ordered Mortgage Master to pay a civil penalty of $425,000, correct and resubmit its 2011 HMDA data, and develop and implement an effective HMDA compliance management system to prevent future violations of the Home Mortgage Disclosure Act (HMDA).
Consent order ()
PDF of this document (14 pages)
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In the Matter of:
UNITED STATES OF AMERICA CONSUMER FINANCIAL PROTECTION BUREAU ADMINISTRATIVE PROCEEDING File No. 2013-CFPB-0006 CONSENT ORDER Mortgage Master, Inc.
The Consumer Financial Protection Bureau ("CFPB"), through its examiners and other staff, has conducted an examination of the processes for managing compliance with Federal consumer financial laws implemented by Mortgage Master (hereinafter "Respondent" as defined below), and identified violations of law and deficiencies in the applicable compliance systems with respect to Respondent's compliance with the Home Mortgage Disclosure Act ("HMDA"), 12 U.S.C. §§ 2801-2810, and its implementing regulation, Regulation C, 12 C.F.R. pt. 1003. The CFPB hereby issues, pursuant to 12 U.S.C. §§ 5563 and 5565, this Consent Order ("Order"). Article I Jurisdiction l. The CFPB has jurisdiction to enforce HMDA pursuant to the Consumer Financial Protection Act ("CFPA"), 12 U.S:C. § 5481 et seq., and 12 U.S.C. §§ 2804(b) and (d). 2. Respondent is a "covered person" as that term is defined by 12 U.S.C. § 5481 (6). 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 1 of 14
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3. Respondent is a nondepository covered person within the meaning of 12 U.S.C. § 5514(a)(1)(A).
4. Respondent is subject to the authority of the CFPB to initiate and maintain an administrative proceeding against it pursuant to 12 U.S.C. § 5563. Article II Stipulation Respondent, by and through its Executive Officers, has executed a "Stipulation and Consent to the Issuance of a Consent Order," dated September 23, 2013 ("Stipulation"), which is incorporated by reference and is accepted by the CFPB. By this Stipulation, Respondent has consented to the issuance ofthis Order by the CFPB pursuant to Sections 1053 and 1055 of the CFPA, 12 U.S.C. §§ 5563 and 5565, without admitting or denying any ofthe allegations, except that Respondent admits the CFPB's jurisdiction over Respondent and the subject matter of this action.
Article III Definitions For purposes of this Order, the following definitions shall apply: I. "Executive Officers" shall mean Respondent's Founder, Chief Executive Officer, Treasurer, President, Vice President and Chief Operating Officer, Chief Financial Officer, Chief Compliance Officer, Board of Directors, and Managing Director of National Sales. 2. "Effective Date" shall mean the date on which the Order is issued. 3. "HMDA data" are mortgage loan data submitted in accordance with HMDA, 12 U.S.C. § 2803, and Regulation C, 12 C.F.R. § 1003.4. 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 2 of 14
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4. "HMDA Loan Application Register" or "HMDA-LAR" is the compilation of information about each applicant or borrower, reported on a loan-by-loan, application-by-application basis in accordance with HMDA, Regulation C, and the staff commentary. 5. "Regional Director" shall mean the CFPB's Regional Director for the Northeast Region. 6. "Respondent" shall mean Mortgage Master, Inc., including Mortgage Master, Mortgage Master Pacific, and Mortgage Master Inc. of Massachusetts, and its successors and assigns. 7.
"Service Provider" shall have the same meaning as that term is defined in Section 1002 of the CFPA, 12 U.S.C. § 5481(26).
Article IV Findings of Fact and Conclusions of Law Based on information collected through the CFPB's examination and supervision of Respondent's compliance with HMDA, including review of Respondent's processes for managing compliance with HMDA and completion of a data integrity review of Respondent's HMDA data, the CFPB finds, and Respondent neither admits nor denies, the following: 1. Respondent reported data on 21,015 loans in its 2011 HMDA-LAR. 12 C.F.R. § 1003.2. 2. Respondent is a for-profit mortgage-lending institution that in 2010 originated home purchase loans, including refinancings of home purchase loans, that equaled at least I 0% of its total loan-origination volume measured in dollars. 12 C.F.R. § 1003.2. 3. As of December 31,2010, Respondent had a home or branch office in a Metropolitan Statistical Area. 12 C.F .R. § 1 003 .2.
4. In 20 I 0, Respondent originated at least 100 home purchase loans, including refinancings of home purchase loans. 12 C.F.R. § 1003.2.
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5. Respondent is a for-profit mortgage-lending institution required to report HMDA data as defined in Regulation C, 12 C.F.R. § 1003.2.
6. In February 2009, the Commonwealth of Massachusetts Division of Banks (Massachusetts DOB) reviewed Respondent's 2007 HMDA-LAR and found that Respondent's HMDA error rates exceeded applicable resubmission thresholds. In June 2010, the Massachusetts DOB and Respondent reached a settlement agreement requiring that Respondent (1) establish, implement, enhance, and continue to maintain procedures and internal controls to ensure compliance with HMDA's loan reporting requirements; (2) review, correct, andre-file all errors within its 2007 HMDA-LAR for mortgage loans and applications in Massachusetts; (3) establish, implement, and maintain operating policies and training procedures to ensure that personnel understand HMDA's reporting requirements; (4) prepare and submit a written report to the Massachusetts DOB describing the HMDA data that were re-filed; and (5) pay a $25,000 administrative penalty.
7. Massachusetts DOB's March 2012 exam report included findings from its data integrity review of Respondent's 2009 and 2010 HMDA-LARs and concluded that Respondent's HMDA error rates exceeded applicable resubmission thresholds. 8. Massachusetts DOB's July 2012 visitation report included findings from its review of Respondent's 2010 and 2011 HMDA-LARs and concluded that Respondent's HMDA error rates exceeded applicable resubmission thresholds.
9. In May 2012, the Bureau initiated a data integrity review of Respondent's 2011 HMDA- LAR. Based on the Bureau's data integrity review of a 32-loan sample of Respondent's HMDA-LAR for the calendar year 2011 , the sample error rate of Respondent's 20 ll HMDA data unreasonably exceeds the CFPB resubmission threshold. 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 4 of 14
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I 0. While Respondent maintained a HMDA compliance system, the system did not maintain procedures "reasonably adapted to avoid such errors," 12 C.F.R. § I 003.6(b ), in its HMDA- LAR.
II. Respondent's HMDA data submissions for the calendar year of 2011 violated HMDA, 12 U.S.C. § 2803, and Regulation C, 12 C.F.R. § 1003.4. Article V Order to Cease and Desist and to Take Other Affirmative Action IT IS HEREBY ORDERED, pursuant to Sections I 053 and I 055 of the CFPA, that Respondent and its officers. agents, representatives, and employees shall cease and desist, and that Respondent shall ensw ~ that its Service Providers or other agents cease and desist, from violating HMDA and Regulation C. It is further ordered that: I. Within 60 days from the Effective Date, Respondent shall submit to the Regional Director written evidence confirming that Respondent has reviewed, fully corrected, and resubmitted its 20 II HMDA data to the Board of Governors of the Federal Reserve System, which collects HMDA data on behalf of the CFPB.
2. Within 30 days of the Effective Date, Respondent shall retain one or more independent consultants, with specialized experience in HMDA compliance, not subject to any conflictof interest, and acceptable to the Regional Director, to conduct a review of Respondent's program to manage compliance with HMDA.
a. The review shall include all systems, programs, policies, and procedures to ensure the accuracy of, and to prevent, identify, and correct errors in, HMDA data. 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 5 of 14
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b. Within 60 days of the Effective Date, the independent consultant shall submit to Respondent/the Executive Officers a written report detailing the findings of the review ("Consultant Report").
3. Within 60 days of receiving the Consultant Report, Respondent shall submit to the Regional Director for review and non-objection a comprehensive written compliance plan designed to ensure that Respondent is in compliance with HMDA, has in place a compliance management system that ensures the accuracy of HMDA data, and prevents, identifies, and corrects any errors in the HMDA data ("Compliance Plan"). The Regional Director shall have the discretion to make a determination of non-objection to the Compliance Plan or direct Respondent to revise it. In the event the Regional Director directs Respondent to revise the Compliance Plan, Respondent shall make revisions and resubmit the Compliance Plan to the Regional Director within 30 days. Upon notification that the Regional Director has made a determination of non-objection to the Compliance Plan, Respondent shall implement and adhere to the steps, recommendations, deadlines, and timeframes set forth in the Compliance Plan.
4. The Compliance Plan shall include, at a minimum:
a.
Detailed steps for addressing each action required by this Order; b. Detailed steps to be taken by Respondent's directors, officers, employees, and agents to:
1. Develop and implement any necessary improvements to Respondent's HMDA compliance management system including policies, procedures, and internal controls to ensure compliance with the data collection and reporting requirements set forth in HMDA and Regulation C, including quarterly 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 6 of 14
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reviews of HMDA reporting requirements as outlined in 12 C.F .R. § 1003.4(a);
11. Develop and implement any necessary improvements to Respondent's compliance program to regularly test HMDA data integrity; and 111. Develop and implement any necessary improvements to Respondent's operating policies and training procedures to ensure that personnel understand HMDA standards and reporting requirements.
c. A copy of the Consultant Report and detailed steps to be taken by Respondent's directors, officers, employees, and agents to:
1. Correct any deficiencies identified in the Consultant Report; and 11. Implement any recommendations or explain why a particular recommendation is not being implemented.
d. Specific timeframes and deadlines for implementation of the steps described above. 5. Within 120 days of the Effective Date, and quarterly thereafter for one year, and at any time in the following four years thereafter upon the CFPB's request within 21 days, Respondent shall submit to the Regional Director a true and accurate written Compliance Progress Report, which has been approved by the Executive Officers, and which shall at a minimum: a. Separately list each action required by the Compliance Plan and this Consent Order; and b. Describe the status of each action, including the action(s) taken or to be taken to comply with each action listed pursuant to subparagraph (a). 6. For a period of five years from the Effective Date, Respondent shall notify the CFPB of any change in Respondent that may affect compliance obligations arising under this Order, at 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 7 of 14
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least 30 days prior to such change, 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 Order; the proposed proceedings or filings related to bankruptcy or insolvency by or against Respondent; or a change in Respondent's name or address. Provided, however, that with respect to any proposed change about which Respondent learns less than 30 days prior to the date such action is to take place, Respondent shall notify the CFPB as soon as is practicable after obtaining such knowledge.
Article VI Role of the Executive Officers IT IS FURTHER ORDERED that:
I. The Executive Officers shall review all submissions (including plans, reports, programs, policies, and procedures) required by this Order prior to submission to the CFPB. 2. Although this Order requires Respondent to submit certain documents for review and nonobjection by the Regional Director, the Executive Officers shall have the ultimate responsibility for proper and sound management of Respondent. 3. In each instance in this Order in which the Executive Officers are required to ensure adherence to, or undertake to perform certain obligations of, Respondent, the Executive Officers shall:
a. Authorize and adopt such actions on behalf of Respondent as may be necessary for Respondent to perform its obligations and undertakings under the terms of this Order; b. Require the timely reporting by Respondent management of such actions directed to be taken by Respondent under the terms of this Order; and 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 8 of 14
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c.
Require corrective action be taken in a timely and appropriate manner of any material non-compliance with such actions.
Article VII Distribution of the Order IT IS FURTHER ORDERED that:
1. Within 30 days of the Effective Date, Respondent shall deliver a copy of this Order to each of its Executive Officers.
2. For a period of three years from the Effective Date, Respondent shall deliver a copy of this Order to any future Executive Officers within 30 days that an individual becomes an Executive Officer.
3. Respondent shall secure a signed and dated statement acknowledging receipt of a copy of this Order, with any electronic signatures complying with the requirements of theE-Sign Act, I 5 U.S.C. § 700I et seq., within 30 days of delivery, from all persons receiving a copy of this Order pursuant to this Article.
Article VIII Record keeping IT IS FURTHER ORDERED that Respondent shall create the following business records:
I. All documents and records necessary to demonstrate full compliance with each provision of this Order, including but not limited to, reports submitted to the CFPB pursuant to Article V and copies of acknowledgments of receipt of this Order required by Article VII. 2. All business records required to be created pursuant to this Article shall be retained for at least 5 years, and shall be made available upon request to CFPB representatives. 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 9 of 14
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Article IX Notices IT IS FURTHER ORDERED that, unless otherwise directed in writing by a CFPB representative, all submissions, requests, communications, consents or other documents relating to this Order shall be in writing and shall be sent by overnight courier (not the U.S. Postal Service) as follows :
To the CFPB:
Steve Kaplan Regional Director, CFPB Northeast Region Consumer Financial Protection Bureau 140 East 45th Street, 4th Floor New York, NY 10017 The subject line shall begin: In re Mortgage Master, File No. 20 13-CFPB-0006. To Respondent:
Paul Anastos President Mortgage Master, Inc.
102 Elm Street Walpole, MA 02081 Robert Kerwin Chief Legal Officer Mortgage Master, Inc.
102 Elm Street Walpole, MA 02081 Mitchel H. Kider Weiner Brodsky Kider PC 1300 19th Street, N.W.
5th Floor Washington, DC 20036 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 10 of 14
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Article X Order to Pay Civil Money Penalty IT IS FURTHER ORDERED that:
1. Pursuant to Section 1 055(c) of the CFPA, 12 U.S.C. § 5565(c), by reason of the alleged violations of law and regulations set forth in Article IV of this Order, and taking into account the factors set forth in 12 U.S.C. § 5565(c)(3), Respondent shall pay a civil money penalty of $425,000 to the CFPB, as directed by the CFPB and as set forth herein. 2. Within 10 days of the Effective Date, Respondent shall pay the civil money penalty in the form of a wire transfer to the CFPB or to such agent as the CFPB may direct, and in accordance with wiring instructions to be provided by counsel for the CFPB. 3. The civil money penalty paid pursuant to this Order shall be distributed to the Civil Penalty Fund of the CFPB in accordance with Section 1 017(d) of the CFPA, 12 U.S.C. § 5497(d). 4. In the event of any default on Respondent's obligation to make payment under this Article, interest, computed pursuant to 28 U .S.C. § 1961, as amended, shall accrue on any outstanding amounts not paid from the date of default to the date of payment, and shall immediately become due and payable.
5. Respondent shall relinquish all dominion, control, and title to the funds paid to the fullest extent permitted by law. Respondent shall make no claim to or demand for return of the funds, directly or indirectly, through counsel or otherwise. 6. In accordance with 31 U.S.C. § 7701 , Respondent, unless it has already has done so, shall furnish to the CFPB its taxpayer identifying numbers, which shall be used for purposes of collecting and reporting on any delinquent amount arising out of this Order. 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 11 of 14
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7. Respondent shall treat the civil money penalty as a penalty paid to the government for all purposes. Regardless of how the Bureau ultimately uses those funds, Respondent shall not: a. Claim, assert, or apply for a tax deduction or tax credit with regard to any federal, state, or local tax for any civil money penalty that Respondent pays pursuant to this Order; or b. Seek or accept, directly or indirectly, reimbursement or indemnification from any source, including but not limited to payment made pursuant to any insurance policy, with regard to any civil money penalty that Respondent pays pursuant to this Order. 8. To preserve the deterrent effect ofthe civil money penalty, if Respondent receives any reimbursement or indemnification from any source, including but not limited to payment made pursuant to any insurance policy, or if Respondent secures a tax deduction or tax credit with regard to any federal, state or local tax, Respondent shall notify the CFPB and pay the amount of the reimbursement, indemnification, tax deduction, or tax credit to the U.S. Treasury within 30 days of receiving same. Such a payment shall not be deemed an additional civil money penalty and shall not be deemed to change the amount of the civil money penalty imposed in this action.
Article XI Compliance and Extensions of Time IT IS FURTHER ORDERED that:
Upon a written showing of good cause, the Regional Director may, in his/her discretion, modify any non-material provisions of this Order (e.g., reasonable extensions of time). Any such modification by the Regional Director shall be in writing. 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 12 of 14
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Article XII Other Provisions 1. Except as set forth in Paragraph 2 of this Article, the provisions of this Order shall not bar, estop, or otherwise prevent the CFPB, or any other federal or state agency or department, from taking any other action against Respondent.
2. The CFPB releases and discharges Respondent from all potential liability for violations of law that have been or might have been asserted by the CFPB based on the practices described in Article IV of this Order, to the extent such practices occurred prior to the Effective Date and are known to the CFPB as of the Effective Date. Notwithstanding the foregoing, the practices alleged in this Order may be utilized by the CFPB 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 calculate the amount of any penalty. This release shall not preclude or affect any right of the CFPB to determine and ensure compliance with the terms and provisions of the Order, or to seek penalties for any violations thereof.
3. This Order is intended to be, and shall be construed to be, a final order issued pursuant to 12 U.S.C. § 5563, and expressly does not form, and may not be construed to form, a contract binding the CFPB or the United States.
4. This Order shall terminate five years from the Effective Date. During that time, the Order shall remain effective and enforceable, except to the extent that any provisions of this Order shall have been amended, suspended, waived, or terminated in writing by the CFPB or its designated agent.
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5. Calculation oftime limitations shall run from the Effective Date and shall be based on calendar days, unless otherwise noted.
6. The provisions ofthis Order shall be binding upon Respondent, its officers, agents, servants, employees, and attorneys, and any successors and assigns thereof. 7. The provisions of this Order shall be enforceable by the CFPB. Any violation of this Order may result in the imposition by the CFPB of additional civil money penalties, as allowed under Section 1055(c) ofthe CFPA, 12 U.S.C. § 5565(c).
8. The provisions of this Order shall be severable and, should any provisions be declared by a court of competent jurisdiction to be unenforceable, the other provisions shall remain in full force.
9. The terms of this Order are controlling, notwithstanding any prior expression, prior agreements, or prior arrangements between the parties, whether oral or written. I 0. Nothing in this Order or the accompanying Stipulation shall be construed as allowing Respondent, its Executive Officers, or employees to violate any law, rule, or regulation. IT IS SO ORDERED, this 9th day of October, 2013.
Richard Cordray Director Consumer Financial Protection Bureau 2013-CFPB-0006 Document 1 Filed 10/09/2013 Page 14 of 14
Stipulation ()
PDF of this document (6 pages)
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UNITED STATES OF AMERICA CONSUMER FINANCIAL PROTECTION BUREAU File No. 2013-CFPB-0006 In the matter of:
Mortgage Master, Inc.
STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER The Consumer Financial Protection Bureau ("CFPB") intends to initiate an administrative proceeding against Mortgage Master, Inc. ("Respondent"), pursuant to 12 U.S.C. §§ 5563 and 5565, for its violation of the Home Mortgage Disclosure Act ("HMDA"), 12 U.S.C. §§ 2801 - 2810, and its implementing regulation, Regulation C, 12 C.F.R. pt. 1003. Respondent, in the interest of compliance and cooperation, and without admitting or denying any wrongdoing, consents to the issuance of the Consent Order, to which this Stipulation and Consent to the Issuance of a Consent Order is attached ("Consent Order"). This Stipulation incorporates the definitions provided in Article III of the Consent Order. In consideration of the above premises, Respondent, through its Executive Officers and duly elected and acting Board ofDirectors, stipulates and agrees to the following: Article I Jurisdiction 1. The CFPB has jurisdiction over this matter pursuant to Sections 1053 and 1055 of the Consumer Financial Protection Act ("CFPA"), 12 U.S.C. §§ 5563 and 5565. 2013-CFPB-0006 Document 2 Filed 10/09/2013 Page 1 of 6
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Article II Consent 2. Respondent, without admitting or denying any wrongdoing, consents and agrees to the issuance of the Consent Order.
3. Respondent admits the CFPB's jurisdiction over Respondent and the subject matter of this action.
4. Respondent consents and agrees that the Consent Order shall be deemed an "order issued with the consent of the person concerned" pursuant to 12 U.S.C. § 5563(b)(4), and consents and agrees that the Consent Order shall become a final order, effective upon issuance, and shall be fully enforceable by the CFPB pursuant to 12 U.S.C. §§ 5563(d)(l) and 5565.
5. Respondent enters into this Stipulation and Consent Order voluntarily. 6. The Consent Order resolves only the claims asserted against Respondent in this civil proceeding. Respondent acknowledges that no promise or representation has been made by the CFPB or any member, officer, employee, agent, or representative of the CFPB, with regard to any criminal liability or civil liability outside of this action that may have arisen or may arise from the facts underlying this action or immunity from any such criminal liability.
7. Respondent agrees that the facts set forth in Article IV of the Consent Order shall be taken as true and be given collateral estoppel effect, without further proof, in any proceeding before the CFPB to enforce the Consent Order, or in any subsequent civil litigation by the CFPB to enforce its rights to any payment or monetary judgment pursuant to the Consent Order.
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8. The terms and provisions of this Stipulation and the Consent Order shall be binding upon, and inure to the benefit of, the parties hereto and their successors in interest. Nothing in this Stipulation or the Consent Order, express or implied, shall give to any person or entity, other than the parties hereto, and their successors hereunder, any benefit or any legal or equitable right, remedy, or claim under this Stipulation or the Consent Order.
9. Respondent agrees that the CFPB may present the Consent Order to the CFPB Director for signature and entry without further notice. 10. Each Director and Executive Officer signing this Stipulation attests that a Board Resolution or other measure of the company authorizing the consent of the Respondent to the issuance of the Consent Order and the execution of the Stipulation was duly approved. This Stipulation may be executed in counterparts by the Directors and Executive Officers after approval of execution of the Stipulation. A copy of the Board Resolution or other measure authorizing execution of this Stipulation shall be delivered to the Bureau, along with the executed original(s) of this Stipulation.
Article III Waivers 11. Respondent, by consenting to this stipulation, hereby waives: a. Any right to service of the Consent Order, and agrees that issuance of the Consent Order will constitute notice to the Respondent of its terms and conditions;
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b. Any objection to the jurisdiction of the CFPB, including, without limitation, under section 1053 ofthe CFPA;
c. The rights to the issuance of a notice of charges; all hearings pursuant to the statutory provisions under which the proceeding is to be or has been instituted; the filing of proposed findings of fact and conclusions of law; proceedings before, and a recommended decision by, a hearing officer; all post-hearing procedures; and any other procedural right available under 12 U.S.C. § 5563 or 12 C.F.R. Part 1081;
d. The right to seek any administrative or judicial review of the Consent Order; e. Any claim for fees, costs or expenses against the CFPB, or any of its agents or employees, and any other governmental entity, related in any way to this enforcement matter or the Consent Order, whether arising under common law or under the terms of any statute, including, but not limited to, the Equal Access to Justice Act and the Small Business Regulatory Enforcement Fairness Act of 1996; for these purposes, Respondent agrees that Respondent is not the prevailing party in this action because the parties have reached a good faith settlement;
f.
Any other right to challenge or contest the validity of the Consent Order; g. Such provisions of the CFPB' s rules or other requirements of law as may be construed to prevent any CFPB employee from participating in the preparation of, or advising the Director as to, any order, opinion, finding of fact, or conclusion of law to be entered in connection with this Consent Order; and 2013-CFPB-0006 Document 2 Filed 10/09/2013 Page 4 of 6
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h. Any right to claim bias or prejudgment by the Director based on the consideration of or discussions concerning settlement of all or any part of the proceeding.
MORTGAGE MASTER, INC. BY:
Paul Anasto/ Date President, Mortgage Master, Inc.
xecutive Officers of Mortgage Master, Inc. each acknowledges g Stip ation and related Consent Order and agrees to the consent aster, I c., but sign in their official capacity only and are not parties to the Date Chairman and CEO, Mortgage Master, Inc. Ann Thomsen Date Director, Mortgage Master, Inc.
Paul Anastos/ Date President, Mortgage Master, Inc ..
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Patricia Raymo Date VP and Chief Operating Officer, Mortgage Master, Inc. David Harrington Date Chief Financial Officer, Mortgage Master, Inc. 2013-CFPB-0006 Document 2 Filed 10/09/2013 Page 6 of 6