(a) Norwich Commercial must establish, implement, and maintain procedures to ensure that the Licensee is capable of compiling and generating an accurate and complete loan list upon request from the Regulators that correctly reflects all loan applications originated by the Licensee.  Procedures implemented pursuant to paragraph (4) shall also require that personnel at each branch office location are able to provide accurate records to the Regulators upon request.

(b) Norwich Commercial must implement procedures to ensure that all reports which are completed by the Licensee and submitted to the Regulators, are accurate and reliable accounts of the reported conditions and/or transactions.

(c) Norwich Commercial must establish, implement and maintain procedures to ensure that the Licensee retains complete loan files, including without limitation, documentation reflecting each loan application’s outcome.

(a) Norwich Commercial must reimburse the borrowers identified in the Report for any duplicate discharge/release fees that were collected.  With its response to the Report, Norwich Commercial shall submit to the Massachusetts Division evidence of the reimbursements/refunds issued pursuant to this subparagraph (a) of paragraph (5).  Evidence shall include the consumers’ names, the amounts of the reimbursements, the dates of the reimbursements, copies of the refund checks, and copies of certified mail receipts to illustrate the borrowers’ receipt of the reimbursements, as appropriate.

(b) Norwich Commercial shall conduct a review of all Massachusetts residential refinance mortgage loans closed since October 16, 2010, to identify transactions in which the borrower was charged duplicate discharge/release fees.  Norwich Commercial shall investigate the loan transactions so identified to determine whether the discharge/release was performed by the Licensee’s closing attorney or by the prior lien holder and, in cases where the closing attorney did not perform the service, to determine whether the full discharge/release fee amount listed on the settlement statement was promptly refunded to the borrower.  With its response to the Report, Norwich Commercial shall submit to the Massachusetts Division a description of the methodology used to complete the portfolio review.

(c) If the investigation of the loan files referenced above identifies cases where appropriate refunds were not issued to the borrower by Norwich Commercial’s closing attorney or settlement agent, Norwich Commercial shall reimburse the affected borrowers for the duplicate fee.  Norwich Commercial shall submit to the Massachusetts Division the results of the portfolio review and any reimbursements issued pursuant to this subparagraph (c) of paragraph (5) within thirty (30) days of the Licensee’s execution of the Stipulation and Consent Agreement.

(a) Norwich Commercial shall submit a payment in the amount of two thousand dollars ($2,000.00) to the Massachusetts Division in satisfaction of an administrative penalty collected in consideration of the Licensee conducting business with a mortgage loan originator who did not hold an active mortgage loan originator license.  Norwich Commercial shall remit payment in full of the amount indicated above, payable to the “Commonwealth of Massachusetts,” with the executed copy of the Stipulation and Consent Agreement, to the Division of Banks, Attn: Mortgage Lender Examination Unit, 1000 Washington Street, 10th Floor, Boston, Massachusetts 02118.

(b) Norwich Commercial shall submit a payment in the amount of six thousand dollars ($6,000.00) to the Connecticut Department as a civil penalty collected in consideration of the Licensee conducting business with a mortgage loan originator who did not hold an active mortgage loan originator license.  Norwich Commercial shall remit payment in full of the amount indicated above, in the form of a cashier’s check, certified check or money order made payable to the “Treasurer, State of Connecticut,” with the executed copy of the Stipulation and Consent Agreement, and sent to State of Connecticut, Department of Banking, Attn: Carmine Costa, Director, Consumer Credit Division, 260 Constitution Plaza, Hartford, Connecticut 06103-1800.

(a) Within thirty (30) days of its execution of the Stipulation and Consent Agreement, Norwich Commercial shall review for accuracy the HMDA data collected for all Massachusetts residential mortgage loans originated during calendar year 2012, and shall re-file corrected information of all erroneous and/or incomplete data previously submitted on the LAR.  Norwich Commercial shall provide the Massachusetts Division with evidence of the resubmission.

(b) Norwich Commercial shall establish, implement, and maintain operating policies and training procedures to ensure that all applicable personnel possess a comprehensive understanding of the HMDA reporting requirements under Regulation C.  Such training shall necessarily ensure the proper implementation and execution of the revised practices and procedures adopted by Norwich Commercial pursuant to this paragraph (8).

(c) Norwich Commercial shall submit to the Massachusetts Division a payment in the amount of twenty-five thousand dollars ($25,000.00) in satisfaction of an administrative penalty collected in consideration of the Licensee’s failure to comply with the statutes, rules and regulations governing the conduct of those engaged in the business of a mortgage lender in Massachusetts.  Norwich Commercial shall remit payment in full of the amount indicated above, payable to the “Commonwealth of Massachusetts,” with the executed copy of the Stipulation and Consent Agreement, to the Division of Banks, Attn: Mortgage Lender Examination Unit, 1000 Washington Street, 10th Floor, Boston, Massachusetts 02118.

(a) A description of the form, content, and manner of any actions taken to address each paragraph of this Joint Consent Order and the results thereof; and

(b) Written findings prepared by Norwich Commercial detailing a review of management’s and staff persons’ adherence to the policies, programs, and procedures adopted pursuant to this Joint Consent Order and to applicable statutes, regulations, and rules, as well as a description of any operational changes implemented during such quarter which are intended to improve Norwich Commercial’s compliance condition in Connecticut and Massachusetts, and the results thereof; and

(c) The reporting requirement to the Regulators referenced in this paragraph 10 shall remain in effect and shall not be amended or rescinded without the prior written modification, termination, or suspension of the applicable provision of this Joint Consent Order from the Connecticut Department and the Massachusetts Division.