On October 19, the Michigan Department of Insurance and Financial Services (DIFS) entered a consent order against a state-licensed mortgage broker, lender, and servicer. The order resolves allegations in a July 20 notice of opportunity to show compliance that the company violated the annual escrow account statement requirements of RESPA’s implementing regulation, Regulation X, the customer information disposal requirements of the FTC’s Safeguards Rule, and several provisions of the state’s Mortgage Brokers, Lenders, and Servicers Licensing Act (MBLSLA). The company accepted the allegations, admitted to violating additional MBLSLA provisions, and waived its right to a hearing before an administrative law judge.

Under the consent order, the company must cease and desist from violating Regulation X and the MBLSLA and must pay a $15,000 civil fine within 30 days of the date on the DIFS invoice. The company must also fully implement its loan servicing software platform by October 31. It must then use the platform to generate a complete servicing loan log as of December 31, 2025, along with escrow analyses, payment histories, and communication logs for 10 servicing files selected during the examination. For two years, the company must retain an independent third party to audit its compliance every six months with: (i) Regulation X’s escrow requirements; (ii) the mortgage servicing practices provisions of TILA’s implementing regulation, Regulation Z; (iii) the FTC’s Safeguards Rule; and (iv) NMLS filing requirements.