DOB: Ameriquest Settlement Agreement State of Connecticut Department of Banking DOB: Ameriquest Settlement Agreement

 

State of Connecticut
Department of Banking

 

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IN THE MATTER OF:

AMERIQUEST MORTGAGE
COMPANY ("Ameriquest")

TOWN & COUNTRY
CREDIT CORPORATION
("Town & Country")

ARGENT MORTGAGE COMPANY,
LLC ("Argent")

ARGENT FUNDING CORPORATION
f/k/a OLYMPUS MORTGAGE COMPANY
("Olympus") 

AMC MORTGAGE SERVICES, INC.
f/k/a BEDFORD HOME LOANS, INC.
("AMC") 

(Collectively "Companies") 

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    SETTLEMENT AGREEMENT    


I. JURISDICTION

The Companies acknowledge the jurisdiction of the Banking Commissioner (the "Commissioner"), neither admit nor deny the Commissioner's allegations contained in this Settlement Agreement, and agree to the terms and conditions of the Settlement Agreement with the Commissioner.

II. APPLICABILITY

This Settlement Agreement shall apply to and bind the Companies on behalf of each of them, their direct and indirect subsidiaries, affiliates, related entities, successors and such assigns (if any) of all or substantially all of the assets (other than mortgage loans) of any such Companies, except as otherwise set forth below. The Settlement Agreement shall apply from and after the date hereof.

III. STIPULATED RECITALS

1. Ameriquest is a Delaware corporation with its principal place of business at 1100 Town & Country Road, Orange, California.
2.  Ameriquest holds 11 licenses (Nos. 2278, 2986, 3152, 3259, 3782, 7015, 7912, 10315, 11644, 11647 and 13531) as a first mortgage lender/broker under Part I(A) of Chapter 668 of the Connecticut General Statutes, "Nondepository First Mortgage Lenders, Brokers and Originators", and its renewal applications for such licenses are currently pending.
3. Ameriquest also holds eight licenses (Nos. 2695, 3267, 3787, 9701, 9702, 9703, 9704 and 11648) as a secondary mortgage lender/broker under Part I(B) of Chapter 668 of the Connecticut General Statutes, "Secondary Mortgage Lenders, Brokers and Originators", and its renewal applications for such licenses are currently pending.
4. Town & Country is a Delaware corporation with its principal place of business at 2010 Main Street, Suite 800, Irvine, California.
5. Town & Country holds five licenses (Nos. 10803, 10959, 12215, 12419 and 12840) as a first mortgage lender/broker under Part I(A) of Chapter 668 of the Connecticut General Statutes, "Nondepository First Mortgage Lenders, Brokers and Originators", and its renewal applications for such licenses are currently pending.
6. Argent is a Delaware limited liability company with its principal place of business at 3 Park Plaza, Irvine, California.
7. Argent holds seven licenses (Nos. 11054, 11055, 11056, 13056, 13286, 13299 and 13300) as a first mortgage lender/broker under Part I(A) of Chapter 668 of the Connecticut General Statutes, "Nondepository First Mortgage Lenders, Brokers and Originators", and its renewal applications for such licenses are currently pending.
8. Argent also holds seven licenses (Nos. 13078, 13079, 13081, 13082, 13083, 13084 and 13285) as a secondary mortgage lender/broker under Part I(B) of Chapter 668 of the Connecticut General Statutes, "Secondary Mortgage Lenders, Brokers and Originators", and its renewal applications for such licenses are currently pending.
9.  Olympus is a Delaware corporation with its principal place of business at 1100 Town & Country Road, Orange, California.
10.  Olympus holds one license (No. 12133) as a first mortgage lender/broker under Part I(A) of Chapter 668 of the Connecticut General Statutes, "Nondepository First Mortgage Lenders, Brokers and Originators", and its renewal application for such license is currently pending.
11.  Olympus also holds one license (No. 12134) as a secondary mortgage lender/broker under Part I(B) of Chapter 668 of the Connecticut General Statutes, "Secondary Mortgage Lenders, Brokers and Originators", and its renewal application for such license is currently pending.
12. AMC is a Delaware corporation with its principal place of business at 2600 Michelson Drive, 6th Floor, Irvine, California.
13. AMC holds one license (No. 12390) as a first mortgage lender/broker under Part I(A) of Chapter 668 of the Connecticut General Statutes, "Nondepository First Mortgage Lenders, Brokers and Originators", and its renewal application for such license is currently pending.
14. AMC also holds one license (No. 12392) as a secondary mortgage lender/broker under Part I(B) of Chapter 668 of the Connecticut General Statutes, "Secondary Mortgage Lenders, Brokers and Originators", and its renewal application for such license is currently pending.
15. Ameriquest, Town & Country, Argent, Olympus, and AMC are all affiliates in that they are under the common control of ACC Capital Holdings Corporation.
16. The Commissioner, through the Consumer Credit Division ("Division") of the Department of Banking, conducted an investigation pursuant to Section 36a-17 of the Connecticut General Statutes into the activities of the Companies to determine if they, or any one of them, had violated, was violating or was about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner.
17. As a result of the investigation described in Paragraph 16, on January 10, 2005, the Commissioner issued a Notice of Intent to Issue Order to Cease and Desist, Notice of Intent to Refuse to Renew First Mortgage Lender/Broker and Secondary Mortgage Lender/Broker Licenses, Notice of Intent to Impose Civil Penalty and Notice of Right to Hearing against Ameriquest and Town & Country (the "Notice").
18. The Notice described in Paragraph 17 alleged that Ameriquest imposed prepaid finance charges in connection with the refinancing of at least 53 mortgage loans that exceeded the greater of five percent of the principal amount of the initial loan or $2,000, which conduct constituted 53 violations of Section 36a-498a of the Connecticut General Statutes, forming the basis for the issuance of an order to cease and desist against Ameriquest, a refusal to renew Ameriquest's first mortgage lender/broker and secondary mortgage lender/broker licenses in Connecticut, and the imposition against Ameriquest of a civil penalty.
19. The Notice described in Paragraph 17 further alleged that Town & Country imposed prepaid finance charges in connection with the refinancing of at least two first mortgage loans that exceeded the greater of five percent of the principal amount of the initial loan or $2,000, which conduct constituted two violations of Section 36a-498a of the Connecticut General Statutes, forming the basis for the issuance of an order to cease and desist against Town & Country, a refusal to renew Town & Country's first mortgage lender/broker licenses in Connecticut and the imposition against Town & Country of a civil penalty.
20. Ameriquest and Town & Country, through their attorneys, requested a hearing concerning the Notice described in Paragraph 17, which hearing was scheduled for March 31, 2005, continued to June 14, 2005, and further continued to September 14, 2005, which hearing will be cancelled upon the effective date of the Settlement Agreement.
21. The Commissioner, through the Division, conducted a further investigation pursuant to Section 36a-17 of the Connecticut General Statutes into the activities of the Companies to determine if they, or any one of them, have violated, was violating or was about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner.
21. The Commissioner, through the Division, conducted a further investigation pursuant to Section 36a-17 of the Connecticut General Statutes into the activities of the Companies to determine if they, or any one of them, have violated, was violating or was about to violate the provisions of the Connecticut General Statutes within the jurisdiction of the Commissioner.
22. As a result of the investigation described in Paragraph 21, the Commissioner has made those certain allegations described below in Paragraphs 23 through 32.
23. In addition to the refinancings described in Paragraph 18, the Commissioner alleges that during the period from January 11, 2003 to January 21, 2004, Ameriquest refinanced at least 80 first mortgage loans for Connecticut consumers and, in connection with such refinancings, imposed prepaid finance charges that when aggregated with the prepaid finance charges imposed on previous financings by Ameriquest or one of its affiliates within two years of the current refinancing exceeded the greater of five percent of the principal amount of the initial loan or $2,000.
24. In addition to the refinancings described in Paragraph 19, the Commissioner alleges that during the period from August 1, 2003 to January 21, 2004, Town & Country refinanced at least 2 first mortgage loans for Connecticut consumers and, in connection with such refinancings, imposed prepaid finance charges that when aggregated with the prepaid finance charges imposed on previous financings by Town & Country or one of its affiliates within two years of current refinancing exceeded the greater of five percent of the principal amount of the initial loan or $2,000.
25. On January 22, 2004, Ameriquest, Town & Country and Argent entered into a Settlement Agreement with the Commissioner imposing sanctions, including a civil penalty, for violations of Section 36a-498a of the Connecticut General Statutes that occurred prior to August 2003.
26. In addition to the refinancings described in Paragraph 23, the Commissioner alleges that during the period from January 22, 2004 to August 1, 2004, Ameriquest refinanced at least 162 first mortgage loans for Connecticut consumers and, in connection with such refinancings, imposed prepaid finance charges that when aggregated with the prepaid finance charges imposed on previous financings by Ameriquest or one of its affiliates within two years of the current refinancing exceeded the greater of five percent of the principal amount of the initial loan or $2,000.
27. In addition to the refinancings described in Paragraph 24, the Commissioner alleges that during the period from January 22, 2004 to November 18, 2004, Town & Country refinanced at least 7 first mortgage loans for Connecticut consumers and, in connection with such refinancings, imposed prepaid finance charges that when aggregated with the prepaid finance charges imposed on the previous financings by Town & Country or one of its affiliates within two years of the current refinancing exceeded the greater of five percent of the principal amount of the initial loan or $2,000.
28. The Commissioner also alleges that during the period from April 25, 2003 to January 25, 2005, Argent refinanced at least 56 first mortgage loans for Connecticut consumers and, in connection with such refinancings, imposed prepaid finance charges that when aggregated with the prepaid finance charges imposed on the previous financings by Argent or one of its affiliates within two years of the current refinancing exceeded the greater of five percent of the principal amount of the initial loan or $2,000.
29. The Commissioner alleges that during the period from April 22, 2004 to April 23, 2004, Olympus refinanced at least 2 first mortgage loans for Connecticut consumers and, in connection with such refinancings, imposed prepaid finance charges that when aggregated with the prepaid finance charges imposed on previous financings by Olympus or one of its affiliates within two years of the current refinancing exceeded the greater of five percent of the principal amount of the initial loan or $2,000.
30. The Commissioner alleges that during the period from January 2, 2003 to August 3, 2004, Ameriquest employed or retained at least 200 originators without first registering such originators under Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes or Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes.
31. The Commissioner alleges that during the period from January 10, 2003 to November 3, 2004, Town & Country employed or retained at least 36 originators without first registering such originators under Sections 36a-485 to 36a 498a, inclusive, of the Connecticut General Statutes or Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes.
32. The Commissioner alleges that during the period from September 23, 2003 to December 29, 2004, AMC employed or retained at least 176 originators without first registering such originators under Sections 36a-485 to 36a 498a, inclusive, of the Connecticut General Statutes, or Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes.
33. The Companies have assured the Commissioner that they are committed to ensuring full compliance with Sections 36a-486(b), 36a-511(b) and 36a-498a of the Connecticut General Statutes and all other applicable laws and have had and continue to have compliance procedures in place to avoid the type of violations described in the Commissioner's allegations above.
34. In connection with Companies' compliance efforts, the Companies have assured the Commissioner that they have taken the following steps voluntarily and without first being requested to do so by the Commissioner:
34.1 That on January, 31 2005, the Companies implemented a policy in Connecticut prohibiting each Company from refinancing any loan made by such Company or any of its affiliates within 2 years of the prior loan (other than loan modifications and refinancing loans made by such Company following the default by a borrower where such loan modification or refinancing loan was made as an accommodation to such borrower in order to eliminate or mitigate the delinquency or other default on such loan).
34.2 That the Companies have implemented systems and procedural changes to assure identification of all affiliate refinances in Connecticut.
34.3 That the Companies have provided restitution and an additional $500 to all Connecticut borrowers who paid amounts in excess of the prepaid finance charge limits under Section 36a-498a.
34.4 That the Companies have implemented monthly, post-funding audits on 100% of their Connecticut refinance loans.
34.5 That the Companies have created a review and reporting process to regularly monitor the pipeline of Connecticut loans to ensure compliance. To support this process, Ameriquest hired associates to monitor the pipeline of Connecticut loans to ensure compliance prior to funding.
34.6 That the Companies have used unaffiliated third-party title companies to perform a "24-month bring down" on title showing all mortgages (past, present, paid in full).
34.7 That the Companies have conducted regression testing following each and every programming change to ensure that no inadvertent change will occur to the compliance programming.


IV. WAIVER OF PROCEDURAL RIGHTS

Subject to the terms and conditions of this Agreement, including the compliance by the Commissioner and the Department of Banking with Paragraph 8 and Paragraph 15 of Part VI below, the Companies, through their execution of this Settlement Agreement, voluntarily waive the following rights as to the matters governed by this Settlement Agreement:

1. A hearing pursuant to Sections 36a-50(a), 36a-51 and 36a-52(a) and 4-177(a) of the Connecticut General Statutes;
2. Proceedings before and a proposed final decision by a presiding officer as provided in Section 4-179 of the Connecticut General Statutes and Section 36a-1-51 of the Regulations of Connecticut State Agencies;
3. To have a written record of the hearing made and a written final decision issued by the Commissioner as provided in Section 4-180 of the Connecticut General Statutes and Section 36a-1-52 of the Regulations of Connecticut State Agencies;
4. All post-hearing procedures pursuant to Sections 36a-1-53, 36a-1-54 of the Regulations of Connecticut State Agencies with respect to the matters described in this Settlement Agreement; and
5. To seek judicial review of, or otherwise challenge or contest the matters described herein, including the validity of this Settlement Agreement, but specifically excluding a breach of this Settlement Agreement by the Commissioner and/or the Department of Banking.


V. ACKNOWLEDGEMENT OF THE COMMISSIONER'S ALLEGATIONS

The Companies, through their execution of this Settlement Agreement, acknowledge the following allegations of the Commissioner, without admitting or denying them:

1. The Commissioner's allegation as to Ameriquest's imposition of prepaid finance charges in connection with the refinancing of at least 295 first mortgage loans that exceeded the greater of five percent of the principal amount of the initial loan or $2,000 constitutes 295 violations of Section 36a-498a of the Connecticut General Statutes, which would form a basis for the issuance of an order to cease and desist against Ameriquest pursuant to Sections 36a-52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew Ameriquest's first mortgage lender/broker and secondary mortgage lender/broker licenses in Connecticut pursuant to Sections 36a 51(a), 36a-494(a)(1)(C) and 36a 517(a)(1)(C) of the Connecticut General Statutes, respectively, and the imposition of a civil penalty against Ameriquest pursuant to Sections 36a-50(a) and 36a 494(b) of the Connecticut General Statutes.
2. The Commissioner's allegation as to Ameriquest's imposition of prepaid finance charges in violation of Section 36a-498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Ameriquest are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Ameriquest's first mortgage lender/broker licenses in Connecticut pursuant to Section 36a-494(a)(1) of the Connecticut General Statutes.
3. The Commissioner's allegation as to Ameriquest's imposition of prepaid finance charges in violation of Section 36a-498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Ameriquest are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Ameriquest's secondary mortgage lender/broker licenses in Connecticut pursuant to Section 36a 517(a)(1) of the Connecticut General Statutes.
4. The Commissioner's allegation as to Ameriquest's employing or retaining of at least 200 unregistered originators constitutes 200 violations of Section 36a-486(b) of the Connecticut General Statutes, which would form a basis for the issuance of an order to cease and desist against Ameriquest pursuant to Sections 36a-52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew Ameriquest's first mortgage lender/broker and secondary mortgage lender/broker licenses in Connecticut pursuant to Sections 36a-51(a), 36a 494(a)(1)(C) and 36a-517(a)(1)(C) of the Connecticut General Statutes, respectively, and the imposition of a civil penalty against Ameriquest pursuant to Sections 36a-50(a) and 36a-494(b) of the Connecticut General Statutes.
5. The Commissioner's allegation as to Ameriquest's employing or retaining of unregistered originators in violation of Section 36a 486(b) of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Ameriquest are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Ameriquest's first mortgage lender/broker licenses in Connecticut pursuant to Section 36a-494(a)(1) of the Connecticut General Statutes.
6. The Commissioner's allegation as to Ameriquest's employing or retaining of unregistered originators in violation of Section 36a 486(b) of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Ameriquest are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Ameriquest's secondary mortgage lender/broker licenses in Connecticut pursuant to Section 36a 517(a)(1) of the Connecticut General Statutes.
7. The Commissioner's allegation as to Town & Country's imposition of prepaid finance charges in connection with the refinancing of at least 11 first mortgage loans that exceeded the greater of five percent of the principal amount of the initial loan or $2,000 constitutes 11 violations of Section 36a-498a of the Connecticut General Statutes, which would form a basis for the issuance of an order to cease and desist against Town & Country pursuant to Sections 36a 52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew Town & Country's first mortgage lender/broker licenses in Connecticut pursuant to Sections 36a-51(a) and 36a 494(a)(1)(C) of the Connecticut General Statutes, and the imposition of a civil penalty pursuant to Sections 36a-50(a) and 36a-494(b) of the Connecticut General Statutes.
8. The Commissioner's allegation as to Town & Country's imposition of prepaid finance charges in violation of Section 36a 498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Town & Country are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Town & Country's first mortgage lender/broker licenses in Connecticut pursuant to Section 36a 494(a)(1) of the Connecticut General Statutes.
9. The Commissioner's allegation as to Town & Country's employing or retaining of at least 36 unregistered originators constitutes 36 violations of Section 36a 486(b) of the Connecticut General Statutes, which would form a basis for the issuance of an order to cease and desist against Town & Country pursuant to Sections 36a-52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew Town & Country's first mortgage lender/broker licenses in Connecticut pursuant to Sections 36a-51(a) and 36a 494(a)(1)(C) of the Connecticut General Statutes, and the imposition against Town & Country of a civil penalty pursuant to Sections 36a-50(a) and 36a-494(b) of the Connecticut General Statutes.
10. The Commissioner's allegation as to Town & Country's employing or retaining of unregistered originators in violation of Section 36a 486(b) of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Town & Country are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Town & Country's first mortgage lender/broker licenses in Connecticut pursuant to Section 36a 494(a)(1) of the Connecticut General Statutes.
11. The Commissioner's allegation as to Argent's imposition of prepaid finance charges in connection with the refinancing of at least 56 first mortgage loans that exceeded the greater of five percent of the principal amount of the initial loan or $2,000 constitutes 56 violations of Section 36a-498a of the Connecticut General Statutes, which would form a basis for the issuance of an order to cease and desist against Argent pursuant to Sections 36a-52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew Argent's first mortgage lender/broker and secondary mortgage lender/broker licenses in Connecticut pursuant to Sections 36a-51(a), 36a 494(a)(1)(C) and 36a 517(a)(1)(C) of the Connecticut General Statutes, respectively, and the imposition against Argent of a civil penalty pursuant to Sections 36a-50(a) and 36a 494(b) of the Connecticut General Statutes.
12. The Commissioner's allegation as to Argent's imposition of prepaid finance charges in violation of Section 36a-498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Argent are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Argent's first mortgage lender/broker licenses in Connecticut pursuant to Section 36a-494(a)(1) of the Connecticut General Statutes.
13. The Commissioner's allegation as to Argent's imposition of prepaid finance charges in violation of Section 36a-498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Argent are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Argent's secondary mortgage lender/broker licenses in Connecticut pursuant to Section 36a 517(a)(1) of the Connecticut General Statutes.
14. The Commissioner's allegation as to Olympus' imposition of prepaid finance charges in connection with the refinancing of at least 2 first mortgage loans that exceeded the greater of five percent of the principal amount of the initial loan or $2,000 constitutes two (2) violations of Section 36a-498a of the Connecticut General Statutes, which could form a basis for the issuance of an order to cease and desist against Olympus pursuant to Sections 36a-52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew Olympus' first mortgage lender/broker and secondary mortgage lender/broker licenses in Connecticut pursuant to Sections 36a-51(a), 36a 494(a)(1)(C) and 36a 517(a)(1)(C) of the Connecticut General Statutes, respectively, and would form the basis of the imposition against Olympus of a civil penalty pursuant to Sections 36a-50(a) and 36a-494(b) of the Connecticut General Statutes.
15. The Commissioner's allegation as to Olympus' imposition of excessive prepaid finance charges in violation of Section 36a-498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Olympus are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Olympus' first mortgage lender/broker licenses in Connecticut pursuant to Section 36a-494(a)(1) of the Connecticut General Statutes.
16. The Commissioner's allegation as to Olympus' imposition of excessive prepaid finance charges in violation of Section 36a-498a of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of Olympus are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew Olympus' secondary mortgage lender/broker licenses in Connecticut pursuant to Section 36a-517(a)(1) of the Connecticut General Statutes.
17. The Commissioner's allegation as to AMC's employing or retaining of at least 176 unregistered originators constitutes 176 violations of Section 36a-486(b) of the Connecticut General Statutes, which would form a basis for the issuance of an order to cease and desist against AMC pursuant to Sections 36a-52 and 36a-494(b) of the Connecticut General Statutes, a refusal to renew AMC's first mortgage lender/broker and secondary mortgage lender/broker licenses in Connecticut pursuant to Sections 36a-51(a), 36a-494(a)(1)(C) and 36a 517(a)(1)(C) of the Connecticut General Statutes, respectively, and would form the basis of the imposition against AMC of a civil penalty pursuant to Sections 36a-50(a) and 36a-494(b) of the Connecticut General Statutes.
18. The Commissioner's allegation as to AMC's employing or retaining of unregistered originators in violation of Section 36a 486(b) of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of AMC are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-485 to 36a-498a, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew AMC's first mortgage lender/broker licenses in Connecticut pursuant to Section 36a 494(a)(1) of the Connecticut General Statutes.
19. The Commissioner's allegation as to AMC's employing or retaining of unregistered originators in violation of Section 36a-486(b) of the Connecticut General Statutes illustrates that the financial responsibility, character, reputation, integrity and general fitness of AMC are not such as to warrant belief that its business will be operated soundly and efficiently, in the public interest and consistent with the purposes of Sections 36a-510 to 36a-524, inclusive, of the Connecticut General Statutes, which would constitute an additional ground to refuse to renew AMC's secondary mortgage lender/broker licenses in Connecticut pursuant to Section 36a-517(a)(1) of the Connecticut General Statutes.

WHEREAS, the Commissioner would have the authority to enter findings of fact and conclusions of law after granting the Companies an opportunity for a hearing;

WHEREAS, the Companies acknowledge the possible consequences of an administrative hearing and voluntarily enter into the terms and conditions of the Settlement Agreement.

VI. SETTLEMENT AGREEMENT

NOW THEREFORE, the Companies and the Commissioner agree as follows:

1. No later than the date the Settlement Agreement is executed by the Companies, the Companies shall have remitted by wire transfer to Brown Raysman Millstein Felder & Steiner LLP, as escrow agent for the Department of Banking, the sum of One Million Dollars ($1,000,000) as a civil penalty (the sums wired to Brown Raysman Millstein Felder & Steiner LLP, as escrow agent under this Paragraph 1 and Paragraph 2 below to be held pursuant to the terms of an Escrow Agreement by and among the Department of Banking, the Companies and Brown Raysman Millstein Felder & Steiner LLP dated as of June 13, 2005);
2. No later than the date this Settlement Agreement is executed by the Companies, the Companies shall remit by wire transfer to Brown Raysman Millstein Felder & Steiner LLP as escrow agent for the Department of Banking the sum of Two Hundred Fifty Thousand Dollars ($250,000) as reimbursement for the Department's costs associated with this matter;
3. No later than the date this Settlement Agreement is executed by the Companies and the Commissioner, the Companies shall enter into a separate Agreement ("Connecticut Housing Assistance Agreement"), pursuant to which the Companies shall document their agreement to contribute to an affordable housing/down payment assistance initiative to be determined by the Commissioner for the benefit of Connecticut consumers.
4. The Companies shall cease and desist from engaging in acts in violation of Sections 36a-486(b) and 36a-498a of the Connecticut General Statutes.
5. The Companies shall take or undertake, as applicable, the following additional compliance procedures with respect to their Connecticut loans:
5.1 The Companies shall continue to utilize recent system and procedural changes and, as necessary, implement further system and procedural changes to assure identification of affiliate refinances.
5.2 The Companies shall continue to conduct monthly, post-funding audits on 100% of their Connecticut refinance loans. This practice will remain in effect until such time as the Commissioner and the Companies agree that such practice is no longer necessary.
5.3 The Companies shall continue to use an unaffiliated third-party title company to perform a "24-month bring down" on title showing all mortgages (past, present, paid in full). This practice will remain in effect until such time as the Commissioner and the Companies agree that such practice is no longer necessary.
5.4 The Companies shall continue to implement system and procedural changes to ensure that leads and loan applications are assigned only to originators registered in Connecticut.
5.5 The Companies shall continue to use a review and reporting process to regularly review the pipeline of Connecticut loans, including the assignment of at least one associate to monitor the pipeline of Connecticut loans to ensure compliance with Sections 36a-498a, 36a-486(b) and 36a-511(b) of the Connecticut General Statutes prior to funding. This practice will remain in effect until such time as the Commissioner and the Companies agree that such practice is no longer necessary.
5.6 The Companies shall continue to conduct regression testing following each and every programming change to ensure that no inadvertent or unintentional changes occur to the compliance programming.
5.7 The Companies shall retain at the expense of the Companies an independent unaffiliated third-party auditor ("Auditor") to be approved by the Commissioner to conduct four semi-annual reviews of the Companies' compliance with Sections 36a-498a, 36a-486(b) and 36a-511(b) of the Connecticut General Statutes. The Commissioner shall establish the scope of the Auditor's reviews, in accordance with this Paragraph 5.7, and the basic content of the Auditor's report. Each review by the Auditor shall be an audit of the loans funded by the Companies and individuals employed or retained as originators requiring registration in Connecticut during a six-month calendar period ("Audit Period"), the first such period to commence on July 1, 2005. The Auditor shall commence each audit no earlier than 61 or later than 70 days after the conclusion of an Audit Period. Following each audit, the Auditor shall provide a written report to the Division with a copy to the Companies detailing the Companies' compliance with Sections 36a-498a, 36a-486(b) and 36a 511(b) of the Connecticut General Statutes. None of the Companies shall discontinue the practices described in Paragraphs 5.2, 5.3, 5.4, and 5.5 and under this subparagraph 5.7 until four such audits demonstrate such compliance to the satisfaction of the Commissioner. After the Auditor completes four such audits and such audits demonstrate such compliance to the satisfaction of the Commissioner, the Companies will be relieved of their obligations under Paragraphs 5.2, 5.3, 5.4, 5.5 and their obligations under this Paragraph 5.7 to undertake semi-annual audits.
6. In the event of future violations of Section 36a-498a, Section 36a-486(b) and/or Section 36a 511(b) of the Connecticut General Statutes:
A. With respect to any future violations of Section 36a-498a of the Connecticut General Statutes:
1. If a violation of Section 36a-498a of the Connecticut General Statutes is discovered by one or more of the Companies, the Company that funded the loan that gave rise to the violation ("Responsible Company") shall: [i] notify the Division in writing of any such violation no later than 60 days after the date the loan that gave rise to the violation ("Subject Loan") was funded; [ii] no later than 90 days after the date the Subject Loan was funded, refund any excess prepaid finance charge with interest to the borrower and provide written notification to the Division of such refund; and [iii] no later than 90 days after the date the Subject Loan was funded, pay to the Department of Banking an administrative fine of $1,000 per Subject Loan. If the Responsible Company complies with the requirements detailed in [i], [ii] and [iii] above, the Responsible Company shall be deemed to have "cured" such violation, and there will be no further consequences with respect to such violation and each such violation so cured will not be counted towards the 25 violation threshold under Paragraph 6.A and Paragraph 7. If a violation of Section 36a-498a of the Connecticut General Statutes is discovered by one or more of the Companies but such violation is not cured within 90 days of the funding of the Subject Loan as provided above, then such violation will be counted towards the 25 violation threshold under Paragraph 6.A and Paragraph 7.
2.

If there are 25 or fewer violations of Section 36a-498a of the Connecticut General Statutes in an Audit Period, for each such violation discovered by the Division or the Auditor retained under Paragraph 5.7, the Responsible Company shall: [i] no later than 30 days after the earlier of the date on which the Responsible Company receives [A] the Auditor's report or [B] the Division's written notification of the violation to the Responsible Company, refund any excess prepaid finance charge with interest to the borrower and provide written notification to the Division of such refund; and [ii] no later than 30 days after the earlier of the date on which the Responsible Company receives [A] the Auditor's report or [B] the Division's written notification of the violation to the Responsible Company, pay to the Department of Banking an administrative fine of $5,000 per Subject Loan. If there are more than 25 such violations of Section 36a-498a of the Connecticut General Statutes during an Audit Period, [a] the Responsible Company shall: [i] no later than 30 days after the earlier of the date on which the Responsible Company receives [A] the Auditor's report or [B] the Division's written notification of the violation to the Responsible Company, refund any excess prepaid finance charge with interest to the borrower and provide written notification to the Division of such refund; and [ii] no later than 30 days after the earlier of the date on which the Responsible Company receives [A] the Auditor's report or [B] the Division's written notification of the violation to the Responsible Company, pay to the Department of Banking an administrative fine of $10,000 per Subject Loan; and [b] the Commissioner may take enforcement action without an administrative hearing as provided below in Paragraph 7. For purposes of this Settlement Agreement, a Company shall be deemed to have received the Auditor's report or the Division's written notification of a violation on [i] the date that such report or such notification, as applicable, is emailed or faxed by 5:00 p.m. eastern time to the Company's email address or facsimile address, as applicable, indicated below; or [ii] the next business day following the day that such report or such notification is sent by overnight (next day) delivery by Federal Express, Airborne, DHL or other comparable national overnight courier service at the Company's address indicated below:

Ameriquest Mortgage Company
1100 Town & Country Road, Suite 1100
Orange, CA 92868

Attn: Adam Bass
Fax: (714) 541-0125
Email: abass@ameriquest.com


Town & Country Corporation
1100 Town & Country Road, Suite 1100
Orange, CA 92868

Attn: Adam Bass
Fax: (714) 541-0125
Email: abass@ameriquest.com

Argent Mortgage Company, LLC
1100 Town & Country Road, Suite 1100
Orange, CA 92868

Attn: Adam Bass
Fax: (714) 541-0125
Email: abass@ameriquest.com

Argent Funding Corporation
f/k/a Olympus Mortgage Company
1100 Town & Country Road, Suite 1100
Orange, CA 92868

Attn: Adam Bass
Fax: (714) 541-0125
Email: abass@ameriquest.com

AMC Mortgage Services, Inc.
f/k/a Bedford Home Loans, Inc.
1100 Town & Country Road, Suite 1100
Orange, CA 92868

Attn: Adam Bass
Fax: (714) 541-0125
Email: abass@ameriquest.com

3. For purposes of this Agreement, the date of funding shall be the earlier of the date of actual funding or 7 calendar days after closing.
4. For purposes of this Paragraph 6 and Paragraph 7, if [i] a Subject Loan has not been discovered, reported and cured by the Responsible Company within the time periods prescribed above in subparagraph 6.A.1 , and [ii] the Division discovers such Subject Loan, then the violation shall be deemed to be a violation discovered by the Division and shall be subject to subparagraph A.5. below.
5. For purposes of this Paragraph 6 and Paragraph 7, if a Subject Loan is discovered by the Division or the Auditor, or if a Subject Loan is discovered by a Responsible Company but not cured, that violation shall be deemed to have occurred on the date of the funding of the Subject Loan and shall count towards the 25 violation threshold for the Audit Period during which such Subject Loan was funded.
B. If any violations of Section 36a-498a of the Connecticut General Statutes which have occurred prior to the date of this Settlement Agreement for which a Responsible Company has not previously provided a refund to the borrowers are discovered by: [i] a Responsible Company, the Responsible Company shall refund any excess prepaid finance charge with interest to the borrower and provide written notification to the Division of the occurrence of such violation and such refund no later than 30 days after the date that the Company has confirmed that such violation has occurred; or [ii] the Division or the Auditor, no later than 30 days after the earlier of the date on which the Responsible Company receives [A] the Auditor's report or [B] the Division's written notification of the violation, as applicable, the Responsible Company shall refund any excess prepaid finance charge with interest to the borrower and during that time frame provide written notification to the Division of such refund. With regard to any violations discovered under [i] or [ii] above there will be no further consequences with respect to any such violation so cured and any such violation will not be counted towards the 25 violation threshold under Paragraph 6.A.
C. With respect to any future violations of Section 36a-486(b) and/or Section 36a-511(b) of the Connecticut General Statutes:

If any individual is employed or retained by any of the Companies and acts as an "originator" in Connecticut within the meaning of Section 36a-485(8) and/or Section 36a-510(5) of the Connecticut General Statutes, without first having been registered as an originator with the Department of Banking in violation of Section 36a 486(b) and/or Section 36a-511(b) of the Connecticut General Statutes, then: (a) if such violation is discovered by the Companies, the Responsible Company shall [i] within 60 days after the date the individual first acted in a manner which would have required registration as an originator under Section 36a-486(b) and/or Section 36a-511(b) of the Connecticut General Statutes, notify the Division in writing of such violation, and [ii] within 90 days after the date the individual first acted in a manner which would have required registration as an originator under Section 36a-486(b) and/or Section 36a 511(b) of the Connecticut General Statutes, pay to the Department of Banking the statutory registration fee and back registration fees, if any, and a $5,000 administrative fine for each such unregistered originator. If the Responsible Company complies with the requirements under [i] and [ii] above, the Responsible Company shall be deemed to have "cured" such violation, and there will be no further consequences with respect to such violation and each such violation so cured will not be counted towards the 25 violation threshold under this subparagraph 6.C.; or (b) if such violation is discovered by the Division or the Auditor, [i] no later than 30 days after the earlier of the date on which the Responsible Company receives [A] the Auditor's report or [B] the Division's written notification of the violation to the Responsible Company, the Responsible Company shall pay to the Department of Banking the statutory registration fee and back registration fees, if any, and a $10,000 administrative fine for each such unregistered originator, and [ii] notwithstanding any such payment, any such violation shall be counted towards the 25 violation threshold under this subparagraph 6.C.

If there are more than 25 violations of Section 36a-486(b) and/or Section 36a-511(b) of the Connecticut General Statutes during an Audit Period, the Commissioner may take enforcement action without an administrative hearing as provided in Paragraph 7.

Anything contained in this Settlement Agreement to the contrary notwithstanding, this Paragraph 6 shall expire 30 days after receipt by the Division of the audit report covering the fourth Audit Period detailed in subparagraph 5.7 and thereafter the provisions of this Paragraph 6 shall have no further force or effect.

7. If the Companies, or any one of them, exceed the violation thresholds set forth in Paragraph 6.A and/or 6.C above, the Commissioner may, in his sole discretion, without an administrative hearing, suspend, revoke or refuse to renew each and all of the Companies' broker/lender licenses upon 10 days notice to the Companies, whether or not any individual Company exceeded the threshold. In the event any one or more of these actions is taken by the Commissioner, the Companies agree to waive any due process rights that the Companies may have, including the procedural rights specified in Part IV herein, but specifically excluding from such waiver any and all rights to seek judicial review of the action taken by the Commissioner under this Settlement Agreement.

Anything contained in this Settlement Agreement to the contrary notwithstanding, this Paragraph 7 shall expire 30 days after receipt by the Division of the audit report covering the fourth Audit Period detailed in Paragraph 5.7 and thereafter the provisions of this Paragraph 7 shall have no further force or effect.

8. On or before 30 days after the date the Settlement Agreement is first published or otherwise announced publicly, the Commissioner shall issue the licenses to the Companies and register the originators as described on Schedule A attached hereto, provided such Companies and originators meet the applicable statutory requirements. For purposes of this Paragraph 8and Paragraphs 12 and 13 below, nothing in this Settlement Agreement shall be deemed to be a failure of such Companies and originators to have met the applicable statutory requirements.
9. This Settlement Agreement and any dispute related thereto shall be construed and enforced in accordance with, and governed by, the laws of Connecticut without regard to any choice of law principles.
10. The Companies enter into this Settlement Agreement voluntarily and represent that no threats, offers, promises, or inducements of any kind have been made by the Commissioner or any member, officer, employee, agent or representative of the Commissioner to induce the Companies to enter into this Settlement Agreement.
11. The Settlement Agreement shall be binding upon the Companies and their successors and assigns. Further, with respect to all conduct subject to this Settlement Agreement and all future obligations, responsibilities, undertakings, commitments, limitations, restrictions, events and conditions, the term "Companies" as used herein shall include the Companies' successors and such assigns (if any) of all or substantially all of the assets (other than mortgage loans) of such Companies.
12. None of the stipulated recitals in Part III hereof and none of the acknowledgements of the Commissioner's allegations in Part V hereof will adversely affect the ability of the Companies or their affiliates to apply for or obtain licensure from the State of Connecticut.
13. None of the stipulated recitals in Part III hereof and none of the acknowledgements of the Commissioner's allegations in Part V hereof will adversely affect the ability of originators, who may be employed or retained by the Companies or their affiliates, to apply for or obtain registrations from the State of Connecticut.
14. This Settlement Agreement concludes the investigation by the Commissioner and any other action, including an administrative hearing, that the Commissioner could commence under Title 36a of the Connecticut General Statutes on behalf of the Connecticut Department of Banking as it relates to the Companies, arising from or relating to the stipulated recitals in Part III hereof and the acknowledgements of the Commissioner's allegations in Part V hereof, provided, however, that excluded from and not covered by this Paragraph are any claims by the Commissioner arising from or relating to enforcement of the Settlement Agreement provisions contained herein.
15. The Commissioner, on behalf of the Department of Banking, hereby fully and completely releases the Companies, their subsidiaries and affiliated companies, and all of their current and former directors, officers, shareholders, employees, insurers and agents, from any and all claims, actions or demands of any kind which could be asserted by the Commissioner and/or the Department based upon the stipulated recitals in Part III hereof, excluding Paragraphs 33 and 34 of Part III, and the acknowledgements of the Commissioner's allegations in Part V hereof.
16. Except for the Connecticut Housing Assistance Agreement and the Escrow Agreement, the Settlement Agreement constitutes the entire agreement between the parties concerning the matters discussed herein. The Settlement Agreement shall not be changed, amended, modified or waived except in writing signed by each party. The provisions of the Settlement Agreement shall be binding upon and inure to the benefit or detriment of the parties hereto and each of their legal successors, subsidiaries, affiliates, partners, underwriters, insurers, officers, directors, shareholders, agents and employees.
17. Entry of this Settlement Agreement by the Commissioner is without prejudice to the right of the Commissioner to take enforcement action against any of the Companies based upon a violation of this Settlement Agreement, if the Commissioner determines that compliance with the terms herein is not being observed or if any representations made by the Companies and reflected herein are subsequently discovered to be untrue. For purposes of this paragraph, a violation of this Settlement Agreement shall be deemed to be a violation of an order of the Banking Commissioner; and
18. This Settlement Agreement shall become final when executed by the Companies and the Commissioner.


Executed at Hartford, Connecticut     ________/s/_________
this 23rd day of June 2005                John P. Burke
                                                      Banking Commissioner

 

I, Adam Bass, state on behalf of Ameriquest Mortgage Company, that I have read the foregoing Settlement Agreement; that I know and fully understand its contents; that I am authorized to execute this Settlement Agreement on behalf of Ameriquest Mortgage Company; that Ameriquest Mortgage Company agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that Ameriquest Mortgage Company voluntarily consents to the issuance of this Settlement Agreement, expressly waiving any right to a hearing on the matters described herein.

By: ________/s/______________
Name: Adam J. Bass
Title: Senior Executive Vice President
Ameriquest Mortgage Company


State of: California
County of: Los Angeles
On this the 15th day of June 2005, before me, Cecilia L. Palmer, the undersigned officer, personally appeared Adam J. Bass, who acknowledged himself/herself to be the Senior Executive Vice President of Ameriquest Mortgage Company, a corporation, and that he/she, as such Senior Executive Vice President, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself/herself as Senior Executive Vice President.

In witness whereof I hereunto set my hand.

Notary Public
Date Commission Expires: 6/1/07

 

I, Adam Bass, state on behalf of Town & Country Credit Corporation, that I have read the foregoing Settlement Agreement; that I know and fully understand its contents; that I am authorized to execute this Settlement Agreement on behalf of Town & Country Credit Corporation; that Town & Country Credit Corporation agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that Town & Country Credit Corporation voluntarily consents to the issuance of this Settlement Agreement, expressly waiving any right to a hearing on the matters described herein.

By: ________/s/______________
Name: Adam J. Bass
Title: Secretary
Town & Country Credit Corporation


State of: California
County of: Los Angeles
On this the 15th day of June 2005, before me, Cecilia L. Palmer, the undersigned officer, personally appeared Adam J. Bass, who acknowledged himself/herself to be the Secretary of Town & Country Credit Corporation, a corporation, and that he/she, as such Secretary, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself/herself as Secretary.

In witness whereof I hereunto set my hand.

Notary Public
Date Commission Expires: 6/1/07

 

I, Adam Bass, state on behalf of Argent Mortgage Company, that I have read the foregoing Settlement Agreement; that I know and fully understand its contents; that I am authorized to execute this Settlement Agreement on behalf of Argent Mortgage Company; that Argent Mortgage Company agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that Argent Mortgage Company voluntarily consents to the issuance of this Settlement Agreement, expressly waiving any right to a hearing on the matters described herein.

By: ________/s/______________
Name: Adam J. Bass
Title: Senior Executive Vice President
Argent Mortgage Company


State of: California
County of: Los Angeles
On this the 15th day of June 2005, before me, Cecilia L. Palmer, the undersigned officer, personally appeared Adam J. Bass, who acknowledged himself/herself to be the Senior Executive Vice President of Argent Mortgage Company, a corporation, and that he/she, as such Senior Executive Vice President, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself/herself as Senior Executive Vice President.

In witness whereof I hereunto set my hand.

Notary Public
Date Commission Expires: 6/1/07

 

I, Adam Bass, state on behalf of Olympus Mortgage Company, that I have read the foregoing Settlement Agreement; that I know and fully understand its contents; that I am authorized to execute this Settlement Agreement on behalf of Olympus Mortgage Company; that Olympus Mortgage Company agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that Olympus Mortgage Company voluntarily consents to the issuance of this Settlement Agreement, expressly waiving any right to a hearing on the matters described herein.

By: ________/s/______________
Name: Adam J. Bass
Title: Senior Executive Vice President
Olympus Mortgage Company


State of: California
County of: Los Angeles
On this the 15th day of June 2005, before me, Cecilia L. Palmer, the undersigned officer, personally appeared Adam J. Bass, who acknowledged himself/herself to be the Senior Executive Vice President of Olympus Mortgage Company, a corporation, and that he/she, as suchSenior Executive Vice President, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself/herself as Senior Executive Vice President.
In witness whereof I hereunto set my hand.

In witness whereof I hereunto set my hand.

Notary Public
Date Commission Expires: 6/1/07

 

I, Adam Bass, state on behalf of AMC Mortgage Services, Inc., that I have read the foregoing Settlement Agreement; that I know and fully understand its contents; that I am authorized to execute this Settlement Agreement on behalf of AMC Mortgage Services, Inc.; that AMC Mortgage Services, Inc., agrees freely and without threat or coercion of any kind to comply with the terms and conditions stated herein; and that AMC Mortgage Services, Inc., voluntarily consents to the issuance of this Settlement Agreement, expressly waiving any right to a hearing on the matters described herein.

By: ________/s/______________
Name: Adam J. Bass
Title: Senior Executive Vice President
AMC Mortgage Services, Inc.


State of: California
County of: Los Angeles
On this the 15th day of June 2005, before me, Cecilia L. Palmer, the undersigned officer, personally appeared Adam J. Bass, who acknowledged himself/herself to be the Senior Executive Vice President of AMC Mortgage Services, Inc., a corporation, and that he/she, as such Senior Executive Vice President, being authorized to do so, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by himself/herself as Senior Executive Vice President.
In witness whereof I hereunto set my hand.

In witness whereof I hereunto set my hand.

Notary Public
Date Commission Expires: 6/1/07

 

Schedule A

List of License Applications
and
Originator Registrations

to be approved by the Commissioner
subject to the terms of the Settlement Agreement

A. Licenses For Town & Country Credit Corporation.

Renewal license applications as follows:

1.  License #10803 -- Corporate office at 2010 Main Street in Irvine, CA
2. License #10959 -- Warwick, Rhode Island, branch office
3. License #12215 -- New London, CT branch office
4. License #12419 -- Rocky Hill, CT branch office
5. License #12840 -- New Haven, CT branch office
B. License Applications For Ameriquest Mortgage Company.

Pending renewal license applications as well as the following new license applications:

1. License application for 3800 American Boulevard West, # 800, Bloomington, Minnesota
2. License application for 5847 San Felipe Plaza, 14th Floor, Houston, Texas
3. License application for 281 Tressor Boulevard, Suite 503, Stamford, Connecticut; and
4. License application for 984 Southford Road, Middlebury, Connecticut
C. Originator Registrations.

As to the applications for registration of originators submitted prior to the date of this Settlement Agreement but as to which the Commissioner has not registered an originator, the Commissioner agrees to register such originators, subject to the terms of this Settlement Agreement and effective as of the time of submission of such applications, provided such originators meet the applicable statutory requirements.


Administrative Orders and Settlements