Unassociated Document


    FEDERAL
DEPOSIT INSURANCE CORPORATION

    


    WASHINGTON,
D.C.

    


    
      	
              In
      the Matter of

            	
              )

            	 
      
	 
      	
              )

            	 
      
	
              FIRST
      MARINER BANK

            	
              )

            	
              ORDER
      TO CEASE AND

            
	
              BALTIMORE,
      MARYLAND

            	
              )

            	
              DESIST,

            
	 
      	
              )

            	
              ORDER
      FOR RESTITUTION,

            
	
              (INSURED
      STATE NONMEMBER BANK)

            	
              )

            	
              AND
      TO ORDER TO PAY

            
	 
      	
              )

            	 
      
	 
      	
              )

            	
              FDIC-07-285b

            
	 
      	
              )

            	
              FDIC-08358k

            
	 
      	
              )

            	 
      


    

     

    First.Mariner
Bank (“Bank”), Baltimore, Maryland, having been advised of its right to a Notice
of Charges and of Hearing detailing the violations of law and regulations
alleged to have been committed by the Bank and of its right to a hearing on the
alleged charges under section 8(b)(1) of the Federal Deposit Insurance Act
(“Act”), 12 U.S.C. § 1818(b)(1), and having waived those rights, entered into a
STIPULATION AND CONSENT TO THE ISSUANCE OF AN ORDER TO CEASE AND DESIST, ORDER
FOR RESTITUTION, AND ORDER TO PAY (“CONSENT AGREEMENT”) with counsel for the.
Federal Deposit Insurance Corporation (“FDIC”), dated March ___, 2009, whereby
solely for the purpose of this proceeding and without admitting or denying any
violations of law and/or regulations, the Bank, consented to the issuance of an
ORDER TO CEASE AND DESIST, ORDER FOR RESTITUTION; AND ORDER TO PAY (“Order') by
the FDIC.


    
      
         


      

      
        
        

        
          

        

      

      
         


      

    

     

    The FDIC
considered the matter and determined that it has reason to believe that the Bank
engaged in a pattern or practice of discrimination in violation of the Equal
Credit Opportunity Act (“ECOA”), 15 U.S.C. §§ 1691-1691f, and its implementing
regulation, Regulation B of the Board of Governors of the Federal Reserve System
(“Regulation B”), 12 C.F.R. Part 202; the Fair Housing Act (“FHA”), 42 U.S.C. §
3601 et seq., and its
implementing regulation, the Fair Housing Act Regulations of the Department of
Housing and Urban Development (“FHA Regulations”), 24 C.F.R. Part 100; and
Section 5 of the Federal Trade Commission Act (“Section 5”), 15 U.S.C. §
45.  The FDIC believes that the Bank engaged in a pattern or practice
of discrimination in violation of ECOA and FHA in 2005, 2006, and 2007 when, for
certain residential mortgage loans, the Bank charged higher prices to certain
Hispanic, Black, and female borrowers, in the form of discretionary interest
rate and point “overages,” than those charged to similarly-situated White or
male borrowers, as applicable.  In addition, the FDIC believes that
the Bank violated Section 5 in 2006 and 2007 in connection with the Bank's
disclosures for its payment-option adjustable-rate mortgage loans (“Option
ARMs”), which contained misleading information regarding the costs of the loans
the borrowers would ultimately receive from the Bank.  The FDIC,
therefore, accepts the CONSENT AGREEMENT and issues the following:

     

    ORDER TO CEASE AND
DESIST

     

    IT IS
HEREBY ORDERED, that the Bank and its institution-affiliated parties, as that
term is defined in section 3(u) of the Act, 12 U.S.C. § 1813(u), cease and
desist from engaging in any act or practice that discriminates on the bases of
race or color, national origin, or sex in violation of ECOA, Regulation B, FHA,
and FHA Regulations.  This prohibition includes, but is not limited
to:

     

    (a)
Operating with policies and practices that violate ECOA and
FHA;


    
      
         


      

      
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    (b)
Failing to adequately monitor residential mortgage loan officers to detect any
act or practice that discriminates against an applicant on the basis of race or
color, national origin, or sex regarding any aspect of a credit transaction in
violation of ECOA and FHA, including identifying any pricing disparities in
loans based on prohibited bases under ECOA and FHA.; and

     

    (c)
Operating without effective fair lending compliance policies and procedures in
place that ensure the Bank's officers, directors, and employees comply with ECOA
and FHA.

     

    IT IS
FURTHER ORDERED, that the Bank and its institution-affiliated parties cease and
desist from providing deceptive disclosures to applicants in violation of
Section 5.  This prohibition includes, but is not limited
to:

     

    (a)
Providing loan applications or disclosures to mortgage loan applicants that
materially understate interest rates, future payment increases, or quote a
temporary initial discounted interest rate or optional minimum payment rate
(hereinafter, “teaser rate”) as the accrual interest rate, when in fact such
rate would potentially or definitely result in negative amortization;
and

     

    (b)
Providing loan applications or disclosures to mortgage loan applicants that cite
a monthly payment amount as a “principal and interest” payment when, in fact,
such payment is based on a teaser rate or would not amortize the
loan.

     

    IT IS
FURTHER ORDERED, that the Bank and its institution-affiliated parties take
affirmative action as follows:


    
      
         


      

      
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    CORRECTIVE
ACTION

     

    Fair
Lending

     

    1. Within
90 days from the effective date of this Order, the Bank shall develop and submit
to the Regional Director for non-objection a formal written policy that requires
the Bank to monitor residential mortgage loan pricing, fees, and overages in a
way that will detect unusual differences, disparities, or patterns and require
appropriate corrective action when detected. The Bank's monitoring program shall
include, at a minimum, the following:

     

    (a)
Development and implementation of a comprehensive system to perform detailed,
quarterly fair lending monitoring analyses to ensure that residential mortgage
loans are priced in a manner that does not violate ECOA or FHA;

     

    (b)
Development and implementation of a comprehensive system to maintain written
records of all Bank offices, divisions, and residential mortgage loan officers
with statistically significant loan pricing disparities based on prohibited
bases under ECOA and FHA;

     

    (c) The
requirement that appropriate measures be taken to ensure that residential
mortgage loan officers discovered to have statistically significant pricing
disparities based on prohibited bases under ECOA and FHA for any quarter receive
counseling and training, where appropriate, and such measures shall be
documented by the Bank; and


    
      
         


      

      
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    (d) The
requirement that the Bank utilize, or continue to utilize, an independent
third-party firm to conduct fair lending analyses of the Bank, and that
supervisory bank loan officers periodically review any reports issued to the
Bank by any such independent third-party firms regarding loan overages of the
residential mortgage loan officers they supervise.

     

    2. Within
90 days from the effective date of this Order, the Bank shall develop and submit
to the Regional Director for non-objection a formal written policy that requires
the Bank to ensure the accuracy and completeness of the data and other
information that the Bank collects regarding mortgage loan applicants, loan
originator compensation, and mortgage loan pricing (“data
integrity”).  The written policy shall require the Bank to establish,
implement, and continuously operate and maintain, a comprehensive data integrity
program designed to ensure compliance with the data integrity policy, which
program shall ensure that any data integrity problems are promptly and
thoroughly corrected.  The Bank shall also retain an independent
third-party firm, subject to non-objection by the Regional Director, that is
qualified to evaluate data integrity to conduct an independent review of the
Bank's data integrity policy and program and provide comments to the Bank and
The Regional. Director.  The Bank's internal audit personnel shall
periodically, but not less than quarterly, validate the Bank's data and report
its findings to the Bank and the. Regional Director.

     

    3. Within
90 days from the effective date of this Order, the Bank shall conduct or
sponsor, in conjunction with an established local or national non-profit
organization, a series of financial literacy courses, which shall occur not less
than quarterly for a period of two years from the effective date of this Order,
in both English and Spanish; in areas in which the. Bank engaged in mortgage
lending, covering topics including, but not limited to, consumer financial
products, budget creation and management, and consumer rights under ECOA and
FHA.


    
      
         


      

      
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    Section
5.

     

    4. Option. ARM
Prohibition: Prior to the issuance of this Order, the Bank ceased
originating, brokering, or offering Option ARMs.  Henceforth and while
this Order remains in force, the Bank shall not originate, broker, or offer
Option ARMs until the Bank has properly established policies and procedures
consistent with the requirements of this Order.

     

    COMPLIANCE POLICIES AND
TRAINING

     

    IT IS
FURTHER ORDERED, that the Bank and its institution-affiliated parties take
affirmative actions as follows:

     

    5. Within
30 days after the Bank receives the Regional Director's non-objection to the
loan monitoring policy required by Paragraph 1 of this Order, the Bank shall
develop and submit to the Regional Director for non-objection an executive
training program, which requires the Bank to provide training to all executive
officers, management, and the Bank's Board of Directors (“Board”) that
encompasses the Bank's fair lending obligations under the ECOA, FHA, the effect
of an ECOA/FHA violation on CRA ratings, the loan monitoring policy required by
Paragraph 1 of this Order, the Bank's obligations under Section 5, and how to
review and utilize the findings of a fair lending analysis conducted by any
independent third-party firm engaged by the Bank.


    
      
         


      

      
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    6. The
Bank, prior to the effective date of this Order, has commenced the provision of
counseling to all loan officers to ensure that applicants are treated equally
regardless of race, ethnicity, or any other prohibited basis.  The
Bank shall continue to provide such counseling and, within 30 days after the
Bank receives the Regional Director's non-objection to the loan monitoring
policy required by Paragraph 1 of this Order, shall develop and submit to the
Regional Director for non-objection an employee training program that includes,
at a minimum:

     

    (a)
Periodic and updated fair lending training to all loan officers and employees
involved in the pricing of loans to ensure that their lending activities are
conducted in a nondiscriminatory manner, and in compliance with ECOA, FHA, and
their implementing regulations, including coverage of the loan monitoring policy
required by Paragraph I of this Order.

     

    (b)
Periodic and updated training to all loan officers and employees involved in the
disclosure or advertisement of loans to ensure that their verbal and written
communications, advertisements, and disclosures are made in compliance with
Section 5 and the guidance set forth in the Interagency Guidance on
Nontraditional Mortgage Product Risks (FIL-89-2006, issued October 5,
2006).


    
      
         


      

      
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    7. The
Bank, prior to the effective date of this Order, has commenced internal reviews
of all residential mortgage loan product disclosures to ensure their accuracy
and compliance with Section 5.  The Bank shall continue to perform
such reviews and, within 90 days from the effective date of this Order, shall
develop and submit to the Regional Director for non-objection a formal written
policy governing communications with consumers to ensure that the borrowers are
provided with sufficient information to enable them to understand all material
terms, costs, and risks of loan products at a time that will help the consumer
select products and choose among payment options, and to ensure that such
information is provided in compliance with Section 5, as well as the guidance
set forth in the Interagency
Guidance on Nontraditional Mortgage Product Risks (FIL-89-2006, issued
October 5, 2006) for nontraditional mortgage products covered by such guidance
(“Policy on Consumer Communications”).  The Policy on Consumer
Communications shall, at a minimum, include the following:

     

    (a)
Provisions that require that all communications with consumers, including
advertisements, oral statements, and promotional materials, provide clear and
balanced information about the relative benefits and risks of the products, and
that such communications shall be provided in a timely manner to assist
consumers in the product selection process, not just upon submission of an
application or at the consummation of the loan.

     

    (b)
Provisions that require that all loan disclosures intentionally directed by the
Bank towards an applicant or applicants who the Bank knows or has reason to
believe have a limited ability to communicate in the English language be
provided in the language of such applicant or applicants, and that all verbal
communications directed to such an applicant or applicants be monitored by the
Bank's supervisory loan officers for compliance with Section 5.

     

    (c)
Provisions that require that all of the Bank's mortgage product descriptions
provide clear, detailed information about all of the costs, terms, features, and
risks of the loan to the applicant, including, but not limited to, the
following:


    
      
         


      

      
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    (i)
Potential payment increases, including how the new payment will be calculated
when the teaser rate expires;

     

    (ii) The
possibility of any negative amortization of the loan;

     

    (iii) The
existence of any prepayment penalty, how it will be calculated, and when it may
be imposed;

     

    (iv) The
existence of any balloon payment;

     

    (v)
Whether there is a pricing premium attached to a reduced documentation or stated
income program; and

     

    (vi)
Whether the borrower will be required to make payments for real estate taxes and
insurance in addition to the loan payment, if not escrowed, and the fact that
tax and insurance costs can be substantial.

     

    8. Operating Plan: The
Bank, prior to the effective date of this Order, has commenced (i) the
submission of ten percent (10%) of the Bank's residential mortgage loan
production to quality control review and (ii) the provision of quarterly reports
to the Bank's Audit Committee by the Bank's Internal Audit, Compliance, and
Quality Control departments. The Bank shall continue to perform such actions
and, within 90 days of the effective date of this Order, shall develop and
submit to the Regional Director for non-objection specific operating policies
and procedures with respect to its internal audit and compliance management
systems (“Operating Plan”) addressing the following areas:


    
      
         


      

      
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    (a) Internal Audit
System: The Bank shall maintain an effective Internal Audit System, which
shall, at a minimum, include policies, procedures and processes that
ensure:

     

    (i)
Adequate monitoring of the Bank's residential mortgage lending activities and
data integrity, through a comprehensive internal audit function;

     

    (ii) An
audit staff comprised of a sufficient number of qualified persons;

     

    (iii) The
independence and objectivity of the internal auditor, the audit staff, and the
Bank's Audit Committee;

     

    (iv)
Adequate testing and review of the Bank's residential mortgage lending
activities such that the scope and testing are adequate to (A) detect
substantive deficiencies in the operation of the Bank's residential mortgage
lending activities; and (B) determine the level of compliance of the Bank and/or
any area or division of the Bank offering residential mortgage loan products
and/or engaging in residential mortgage lending activities with all applicable
federal consumer protection laws, including ECOA, FHA, and Section 5, and all
implementing rules and regulations, regulatory guidance, and statements of
policy as well as all applicable policies and procedures of the
Bank;

     

    (v)
Adequate documentation of tests and findings of any corrective
actions;

     

    (vi)
Verification and review of management actions to address material
weaknesses;


    
      
         


      

      
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     (vii)
Tracking of deficiencies and exceptions noted in audit reports with periodic,
but not less than quarterly, status reports to the Board with each deficiency
and material exception identified, the source of the deficiency or exception and
date noted, responsibility for correction assigned, and the date corrective
action was taken in the report;

     

    (viii)
Review of the effectiveness of the Bank's Internal Audit Systems and/or the
Internal Audit Systems of any other area or division of the Bank offering
residential mortgage loan products or engaging in residential mortgage lending
activities by the Bank's Audit. Committee or Board; and

     

    (ix) An
annual audit schedule for the Bank and/or any other area or division of the Bank
offering residential mortgage loan products or engaging in residential mortgage
lending activities approved by the Board with any planned changes to or
deviations from the approved audit schedule, its scope, or content requiring the
prior written approval of the Board or its Audit Committee appropriately
reflected in the minutes of the meeting wherein the change or deviation was
approved.

     

    (b) Compliance Management System
(CMS): The Bank shall maintain an effective CMS, which shall, at a
minimum, include policies, procedures and processes that ensure that all
residential mortgage loan products and residential mortgage lending activities
comply with all applicable federal consumer protection laws, including ECOA,
FHA, Section 5, and all implementing rules and regulations, regulatory guidance,
including the guidance set forth in the Interagency Guidance on
Nontraditional Mortgage Product Risks (FIL-89-2006, issued October 5,
2006), and statements of policy, and provide for:


    
      
         


      

      
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    (i) Bank
review of periodic, but not less than quarterly, quality assurance
reports;

     

    (ii) Bank
review and monitoring, periodically, but not less than quarterly, of the Bank's
data integrity and effectiveness of the Bank's data integrity
program;

     

    (iii)
Mandatory regular compliance reviews by the Bank, including all policies and
procedures, and internal compliance audits; and

     

    (iv) The
designation of an appropriate officer or director to oversee the CMS, as well as
an appropriate number of compliance personnel with sufficient experience in, and
knowledge of, consumer compliance laws and regulations to administer the
CMS.

     

    MONITORING COMPLIANCE WITH
THIS ORDER

     

    IT IS
FURTHER ORDERED, that. the Bank and its institution-affiliated parties take
affirmative actions as follows:

     

    9. Within
30 days from the effective date of this Order, the Bank shall task its
Community
Action Committee (“CAC”) to monitor compliance with this Order.  The
CAC shall keep minutes of its meetings and have them available for inspection
upon request by the FDIC.

     

    10.
Within 90 days from the effective date of this Order, and every 180 days
thereafter during the life of this Order, the CAC shall submit to the Board for
consideration at its regular monthly meeting, a written report detailing the
Bank's compliance with this Order.  The CAC's compliance report shall
be incorporated into the minutes of the corresponding Board
meeting.  Nothing herein contained shall diminish the responsibility
of the entire Board to ensure compliance with the provisions of this
Order.


    
      
         


      

      
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    11.
Within 30 days of the end of the first calendar quarter following the effective
date of this Order, and within 30 days of the end of each calendar quarter
thereafter, the Bank shall furnish written progress reports to the Regional
Director (“Quarterly Report”).  Each Quarterly Report shall provide a
complete account of the Bank's actions to comply with each requirement of this
Order during the previous quarter, an objective assessment of the extent to
which each quantifiable obligation was met, an explanation of why any particular
component fell short of meeting its goal for that quarter, and any
recommendations for additional actions to achieve the goals of this
Order.  The bank shall attach to each Quarterly Report representative
copies of training material disseminated during the previous quarter pursuant to
this Order.

     

    12. The
Quarterly Reports may be discontinued only following termination of this Order
or when the. Regional Director has otherwise released the Bank in writing from
making further reports.

     

    13. For
the duration of this Order, the Bank shall retain all records relating to its
obligations hereunder, including its lending and training activities and other
compliance, activities as set forth herein.  The FDIC shall have the
right to review and copy such records upon request.

     

    14. The
Bank shall continue to retain during the duration of this Order all
documentation (both electronic and hard copy) relating to all applications for
residential mortgage loans, whether originated or
non-originated.  Non-originated applications include those designated
as “denied,” “withdrawn,” “approved, not accepted,” and
“incomplete.”  This requirement includes all applications for all
residential mortgage loans.


    
      
         


      

      
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    MISCELLANEOUS

     

    15.
Whenever a provision of this Order shall require the Bank to submit a proposed
plan, policy, program, procedure or system; or an enhancement, revision or
addition to a plan, policy, program, procedure, system; or other matter to the
Regional Director for review, comment and/or non-objection, the Bank shall make
such submission to the Regional Director at 20 Exchange Place, New York, New
York 10005.

     

    16. The
Regional Director shall provide comments to the Bank within 30 days of receipt
of the proposed plan, policy, program, procedure or system; or enhancement,
revision or addition to the plan, policy, program, procedure or system; or other
matter submitted for her review, comment and/or non-objection in
writing.

     

    17.
Within 30 days of receipt of comments from the Regional Director, the Bank shall
make such modifications as may be necessary to address the Regional Director's
comments.  If the Bank fails to make such modifications, or otherwise
fails to address the Regional Director's comments within such 30-day period, the
Bank shall provide to the Regional Director a comprehensive written explanation
of its rationale.  Within 30 days of receipt of the Bank's response,
the Regional Director shall either (1) provide in writing a non-objection to the
revisions proposed by-the Bank; or (ii) provide comments as to the rationale for
rejecting the proposed revisions, or such revisions which remain objectionable;
and shall direct the Bank to implement the plan, policy, program, procedure,
system, revision, or enhancement as finally approved.


    
      
         


      

      
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    18. The.
Bank's actions shall be appropriately recorded in the Board meeting minutes.
Thereafter, the Bank and its directors, officers and employees shall fully
implement and follow the plan, policy, program, procedure or system, or other
matter as adopted and shall ensure full and complete compliance with these
plans, policies, programs, procedures or other matters.

     

    ORDER TO PAY
RESTITUTION

     

    19.
Within 5 days of the effective date of this Order, the Bank shall deposit in an
interest-bearing escrow account the total sum of nine hundred fifty thousand
dollars  ($950,000.00) for the purpose of paying the restitution
required by this Order (“Restitution Fund”).  The total amount of
restitution to be made by the Bank pursuant to this Order shall not exceed nine
hundred fifty thousand dollars ($950,000.00), plus the interest that has accrued
on the Restitution Fund.

     

    20.
Within 30 days from the effective date of this Order, which period may be
extended by the Regional Director, the Bank shall make restitution, in the form
of reimbursement, in amounts specified to borrowers to be identified and alleged
by the FDIC as having been charged higher overages in violation of ECOA and FHA
on loans made by the Bank in 2005, 2006 and 2007.  Restitution amounts
specified for particular borrowers shall have been reduced by any amounts
already paid voluntarily by the Bank to such borrowers.  The
restitution shall be made to a particular borrower upon execution of a valid
release by the borrower.  The Bank shall maintain copies of each
restitution check for review by the FDIC at its next examination of the
Bank.


    
      
         


      

      
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    21.
Within 30 days from the effective date of this Order, which period may be
extended by the Regional Director, the Bank shall make restitution in the form
of reimbursement in amounts specified by the FDIC to borrowers identified and
alleged by the FDIC to have been provided deceptive disclosures in violation of.
Section 5. FDIC has identified six (6) borrowers among the foregoing whose
relief shall, at the election of the borrower, consist of either cash
reimbursement in an amount specified by the FDIC, or an offer by the Bank to
refinance the loan into a new affordable loan with terms approved by the
Regional Director.  If in the judgment of the Regional Director a
particular borrower does not meet minimum underwriting standards or cannot
verify income, then that borrower's relief shall be limited to the cash
reimbursement.

     

    (a) The
Bank's letter to the borrowers setting forth this choice shall be in a form
approved by the Regional Director. Any such refinance will be at no cost to the
borrower.  In the event that the borrower elects to refinance, the
cash reimbursement that would have been paid to the borrower shall be applied
toward any out-of-pocket costs to unaffiliated third parties incurred by the
Bank in connection with such refinance and against the borrower's principal
balance on the refinanced loan.

     

    (b) The
restitution described by this paragraph shall be made to a particular borrower
upon execution of a valid release by the borrower.  The Bank shall
maintain copies of each restitution check or loan documents provided in
connection with this paragraph for review by the FDIC at its next examination of
the Bank.


    
      
         


      

      
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    ORDER TO
PAY

     

    IT IS
FURTHER ORDERED THAT, by reason of the alleged violations of law and/or
regulations, and after taking into account the CONSENT AGREEMENT, the
appropriateness of the penalty with respect to the financial resources and good
faith of the Bank, the gravity of the conduct by the Bank, the history of
previous conduct by Bank, and such other matters as justice may require,
pursuant to section 8(i)(2) of the Act, 12 U.S.C. § 1818(i)(2), a civil money
penalty of fifty thousand dollars ($50,000) is assessed against the
Bank.  The Bank shall pay the civil money penalty to the Treasury of
the United States.  The Bank shall pay such civil money penalty
itself, and is prohibited from seeking or accepting indemnification for such
payment from any third party.

     

    SAVINGS
CLAUSE

     

    The
provisions of this Order shall not bar, estop or otherwise prevent the FDIC or
any other Federal or State agency or department from taking any other action or
seeking further remedies against the Bank or any of the Bank's current or former
institution-affiliated parties or agents for violations of any laws, engaging in
unsafe or unsound banking practices, or unfair or deceptive
practices.  The provisions of this Order apply to the Bank's
successors and assigns.


    
      
         


      

      
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    EFFECTIVE
DATE

     

    This
Order shall become effective upon its issuance by the FDIC.  The
provisions of this Order shall remain effective and enforceable except to the
extent that, and until such time as, any provisions of this Order shall have
been modified, terminated, suspended, or set aside by the FDIC.

     

    Pursuant
to delegated authority.

     

    Dated at
Washington, DC this 22nd day of
April, 2009.

     

    
      
        
          	
                  

                
	
                  Sandra
      L. Thompson

                
	
                  Director

                
	
                  Division
      of Supervision and Consumer
Protection

                


        

      

    


    
      
         


      

      
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