Summer Regulatory Summit eBook

Investigation

• Regulator Calls

– Panelist Lightning Round

 What went right on those calls?

 What can be improved for future calls?

 What would you do differently?

– Attender Thoughts?

• Other Investigative Tools

• Timeline

• Alternatives to Enforcement

Timeline - Oregon

2017 – Taylor buys controlling interest 2018 – First net loss of $900k 2019 – Loss of $600k

5/20/21 Fannie Mae suspends Seller/Servicer (does not disclose to state regulators until September 2023) 12/31/22 – Liquidity crunch with upside down current ratio but still profitable on loans held for sale at 4.05 Late 2022 –10/23 – Hometown closes hundreds of FHA and VA loans but does not remit MIP or funding fees 3/31/23 – Back to right side on current ratio at 106, but margin on loans held for sale drops to almost even at 0.89 6/31/23 – Current ratio down slightly to 104, but margin on loans held for sale drops to negative .07 6/23 - 10/23 – MLO count reduces from 400 to 69 8/23 – 9/23 – Hometown contacted borrowers of loans sold to Siwell and told them to send first payment to Hometown not Siwell 9/23 – Loans purchased by Equity Prime from Hometown are not insured when they should be 9/23 – 10/23 – Hometown fails to forward funds on renovation loans to Equity Prime 9/13/23 – Fannie Mae issues Termination 10/5/23 – Notice to states on Hometown & Box invitations sent out 10/6//23 – Staff cut and transition to broker model 10/6/23 – Alabama issues Notice of Intent to Revoke license 10/17/23 – Washington issues temporary C&D 10/30/23 – CA DFPI issues Order Summarily Revoking Residential Mortgage Lender and/or Servicer License 11/2/23 – Montana holds call with former MLO for Hometown Lenders 11/6/23 – Montana issues temporary C&D 11/15/23 – Alabama issues Final Order revoking license 11/17/23 – Ohio issues a Notice of Intent to Revoke 11/22/23 – Kentucky issues Emergency Order of Suspension 11/27/23 – Maine issues C&D 12/28/23 – Montana issues Final Order of Revocation of Licenses and Imposition of Civil Penalties 1/10/24 – Michigan enters Order for Summary Suspension of Registrations 1/10/24 – Montana issues Notice of Violation, Proposed Imposition of Civil Penalties and Opportunity for Administrative Hearing 1/26/24 – Montana issues Final Order and Imposition of Civil Penalties 2/26/24 – Connecticut issues Notice of Automatic Suspension, Notice of Intent to Revoke Mortgage Lender License… 6/3/24 – Hometown Lenders files Chapter 11