Common use of SETTLEMENT TERMS AND CONDITIONS Clause in Contracts

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI is willing to resolve the violations cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations. Therefore, in consideration of the promises and covenants set forth herein: 1. RBI agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; and b. ensuring that its advertisements do not mislead consumers as to the identity of the party offering credit; and c. clearly identifying itself by name and an approved office address located in New York in any advertisement targeted to New York consumers; and d. ensuring that its advertisements do not mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and e. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, and conspicuously all material information. 2. RBI agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters; and (ii) establish a training program to ensure that RBI and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letters. 3. Within ninety (90) days from the effective date of this Agreement, RBI agrees to submit a draft of its advertisement policies and procedures to the Department. 4. Within one hundred twenty (120) days from the effective date of this Agreement, RBI agrees to submit a copy of its final advertisement policies and procedures to the Department together with a letter from an authorized officer of RBI indicating his/her approval of such policies and procedures. 5. RBI further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 6. RBI agrees to pay a fine of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months. 7. RBI further agrees that such payment will be made in immediately available funds in accordance with the Department’s payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI Premium Mortgage is willing to resolve the violations cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations. Therefore, in consideration of the promises and covenants set forth herein, the Settling Parties agree, as follows: 1. RBI Premium Mortgage agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying Complying with the requirements of the Federal Truth-In-Lending Act (Regulation Z), Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; andRegulations; b. ensuring that its advertisements do not mislead consumers as to misrepresent the identity of fees for obtaining financing, including, representing, directly or by implication, that there are no fees associated with obtaining credit when that is not the party offering creditcase; and c. clearly identifying itself by name and an approved office address located in New York in any advertisement targeted to New York consumers; and d. ensuring that its advertisements do not otherwise mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and e. d. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, clearly and conspicuously all material information. 2. RBI Premium Mortgage agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines; and (ii) include a listing of all applicable laws, regulations, and truth in advertising guidelines; (iii) establish a mechanism for ensuring that all applicable laws, regulations, and truth in advertising guidelines are met; (iv) establish a training program to ensure that RBI Premium Mortgage and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letterstruth in advertising guidelines. 3. Within ninety (90) days from the effective date of this Agreement, RBI Premium Mortgage agrees to submit a draft of its advertisement policies and procedures to the Department. 4. Within one hundred twenty (120) days from the effective date of this Agreement, RBI Premium Mortgage agrees to submit a copy of its final advertisement policies and procedures to the Department together with a letter from an authorized officer of RBI Premium Mortgage indicating his/her approval of such policies and procedures. 5. RBI Premium Mortgage further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 65. RBI Premium Mortgage agrees to pay a fine of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months3,000. 76. RBI Premium Mortgage further agrees that such payment will be made in immediately available funds in accordance with the Department’s Department payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI Guaranteed Home is willing to resolve the violations violation cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations. Therefore, in consideration of the promises and covenants set forth herein, the Settling Parties agree, as follows: 1. RBI Guaranteed Home agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of the Federal Truth-In-Lending Act and Regulation Z, Title 18 U.S.C. §709, Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; and b. ensuring that its advertisements do not utilize the name or the seal of any government agency, including HUD and FHA, to imply that the advertisements are from or its services or products have some connection with, authorization from, or are endorsed by such government agency; and c. ensuring that its advertisements do not mislead consumers as to the identity of the party offering credit; and c. clearly identifying itself by name and an approved office address located in New York in any advertisement targeted to New York consumers; and d. ensuring that its advertisements do not otherwise mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and e. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, clearly and conspicuously all material information. 2. RBI Guaranteed Home agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines; and (ii) include a listing of all applicable laws, regulations, and truth in advertising guidelines; (iii) establish a mechanism for ensuring that all applicable laws, regulations, and truth in advertising guidelines are met; (iv) establish a training program to ensure that RBI Guaranteed Home and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letterstruth in advertising guidelines. 3. Within ninety (90) days from the effective date of this Agreement, RBI Guaranteed Home agrees to submit a draft of its advertisement policies and procedures to the DepartmentBanking Department for non-objection or comment. 4. Within one hundred twenty (120) days from the effective date of this Agreement, RBI Guaranteed Home agrees to submit a copy of its final advertisement policies and procedures to the Banking Department together with a letter from an authorized officer of RBI Guaranteed Home indicating his/her approval of such policies and procedures. 5. RBI Guaranteed Home further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 65. RBI Guaranteed Home agrees to pay a fine penalty of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months7,500. 76. RBI Guaranteed Home further agrees that such payment will be made in immediately available funds in accordance with the Department’s Banking Department payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI Franklin First is willing to resolve the violations cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations. Therefore, in consideration of the promises and covenants set forth herein: 1. RBI Franklin First agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of the Federal Truth-In-Lending Act and Regulation Z, Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; andRegulations; b. ensuring that its advertisements do not mislead consumers as to the identity of the party offering credit; and c. clearly identifying itself by name and an approved office address located in New York in any advertisement targeted to New York consumers; and d. ensuring that its advertisements do not mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously conspicuously, the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and; c. ensuring that its advertised offers of credit are consistent with prudent lending practices, as reflected in the Department’s May 25, 2007 Industry Letter on Mortgage Lending Standards and its June 30, 2007 Industry Letter on Subprime Mortgage Lending (collectively, the “Guidance Letters”); d. ensuring that when it advertises any mortgage product, it will provide clear and conspicuous information about the costs, terms, features and risk of such loans; e. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message message(s) of its advertisements, and that it will disclose clearlydisclose, clearly and conspicuously conspicuously, all material information; and f. ensuring that when it advertises an introductory rate or monthly payment amount that may subsequently increase it will disclose, clearly and conspicuously: (i) how long the introductory rate is in effect; (ii) the reset or adjustment period; (iii) the maximum reset rate (if there is one); and (iv) if the advertisement contains a monthly payment amount at an introductory rate, it also will disclose the repayment terms or loan period over the full term of the loan, including the maximum monthly payment amount at the fully indexed rate (taking into consideration the expiration of any negative amortization or interest rate caps, or if there is no interest rate cap, a rate equal to any applicable margin on the loan plus the highest recorded rate during the prior ten years for the index used to calculate the interest rate) and any balloon payments. 2. RBI Franklin First agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters; and (ii) establish a training program to ensure that RBI Franklin First and its MLO and non-MLO employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letters. 3. Within ninety (90) days from the effective date of this Agreement, RBI Franklin First agrees to submit a draft of its advertisement policies and procedures to the Department. 4. Within one hundred twenty (120) days from the effective date of this Agreement, RBI Franklin First agrees to submit a copy of its final advertisement policies and procedures to the Department together with a letter from an authorized officer of RBI Franklin First indicating his/her approval of such policies and procedures. 5. RBI further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 6. RBI Franklin First agrees to pay a fine of $ 7,500 10,000 payable in ten (10) equal monthly installments as follows: $750 1,000 upon execution of this Agreement, and Agreement $750 1,000 each on or before the 15th day of each consecutive month for the immediately following nine (9) months. 76. RBI Franklin First further agrees that such payment will be made in immediately available funds in accordance with the Department’s payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI JBN is willing to resolve the violations cited stated herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations598. Therefore, in consideration of the promises and covenants set forth herein: 1. RBI JBN agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; and; b. ensuring not conducting or transacting New York regulated mortgage business at any location that its advertisements do has not mislead consumers as to been approved by the identity of the party offering credit; andSuperintendent; c. clearly identifying itself not conducting or transacting business in this state under any assumed name or designation using a name that has not been approved by name and an approved office address located in New York in any advertisement targeted to New York consumers; andthe Superintendent; d. ensuring that it will provide appropriate training for its advertisements do not mislead consumers as to employees regarding the terms and conditions establishment of credit it is offering and that such advertisements disclose clearly and conspicuously or the existence change of material terms, conditions, and limitations relating to any advertised offer of credit; andbranch locations; e. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts all individuals engaged in New York regulated mortgage loan activities are duly licensed; f. ensuring that materially contradict or modify the principal message of its advertisementsVOORs submitted are accurate, and will disclose clearly, that JBN maintains supporting documents which can be used to reconcile the information reported in the VOORs; g. ensuring that it reports all revenue from New York regulated forward and conspicuously reverse mortgages in the VOORs; h. ensuring that it maintains for three years and has a list of closing agents available for examination upon request; and i. ensuring that all material informationmortgage applications for New York properties are signed by the employee taking the application. 2. RBI JBN agrees to develop appropriate written advertisement compliance policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines; and (ii) include a listing of all applicable laws and regulations; (iii) establish a mechanism for ensuring that all applicable laws and regulations are met; (iv) establish a training program to ensure that RBI JBN and its employees involved in preparing or approving advertisements establishing new branch locations and utilizing new assumed names understand all applicable federal and state laws, laws and regulations, supervisory requirements and guidance letters. 3. Within ninety (90) days from the effective date of this Agreement, RBI JBN agrees to submit a draft of its advertisement compliance policies and procedures to the Department. 4. Within one hundred twenty thirty (12030) days of receipt of non-objection or any comments from the effective date Department, and after incorporation and adoption of this Agreementall comments, RBI JBN agrees to submit a copy of its final advertisement compliance policies and procedures to the Department together with a letter from an authorized officer of RBI JBN indicating his/her approval of such policies and procedures. 5. RBI further JBN agrees to provide copies pay a penalty of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement$ 15,000. 6. RBI agrees to pay a fine of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months. 7. RBI JBN further agrees that such payment will be made in immediately available funds in accordance with the Department’s payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI Contour is willing to resolve the violations cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations598. Therefore, in consideration of the promises and covenants set forth herein, the Settling Parties agree, as follows: 1. RBI Contour shall not: a. Under any name or designation conduct or transact business in this state at any physical location that has not been approved by the Superintendent; b. Under any name or designation conduct or transact business in this state through the use of any website or domain name that has not been approved by the Superintendent; c. Conduct or transact business under any name or designation other than that shown on its license or branch certificate; d. Assign mortgage loan originators to locations that are not licensed by the Superintendent; e. Engage in net branching or offer net branching opportunities in violation of the Department’s prohibition against net branching; f. Transfer or assign its mortgage banker license; g. Engage in conduct prohibited by Part 38 of the General Regulations. 2. Contour agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, supervisory requirements, and supervisory requirements guidance letters relating to its mortgage business, including, including but not limited to: a. complying Complying with the requirements of Article Banking Law Articles 12-D and 12- E, Part 420 of the Banking LawSuperintendent’s Regulations, and Part 38 of the General Regulations of the Banking Board; andRegulations; b. ensuring that its advertisements do not mislead consumers as Assigning mortgage loan originators only to locations licensed by the identity of Superintendent, and displaying the party offering credit; andlicense for each mortgage loan originator working at such location; c. clearly identifying itself by name Providing the proper oversight and supervision of each individual who becomes employed by, or affiliated as an approved office address located in New York in any advertisement targeted to New York consumersindependent contractor of or consultant for, Contour; and d. ensuring Maintaining books and records in a manner that its advertisements do not mislead consumers as will enable the Superintendent to the terms determine whether Contour is complying with all applicable federal and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material termsstate laws, conditionsregulations, supervisory requirements, and limitations relating guidance letters. 3. Contour agrees to any advertised offer develop a comprehensive operations manual governing its day-to-day operations, which shall, at a minimum, address the: a. Establishment of creditnew business locations; b. Use of business names and designations; c. Activities and supervision of employees, independent contractors, and consultants; and e. ensuring that it will not advertise terms d. Maintenance of credit using footnotes, asterisks, small print books and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, and conspicuously all material informationrecords. 24. RBI Contour agrees to develop appropriate a written advertisement policies and procedures compliance manual designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance letters. The policies and procedures manual shall, at a minimum: (i) designate , address: a. The designation of an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance letters; b. Prohibited conduct as described by Section 38.7 of the General Regulations; c. The duties of an originating entity as described by Part 420 of the Superintendent’s Regulations; d. Reporting requirements as described by Part 420 of the Superintendent’s Regulations; e. Use of business names and designations, domain names, and websites; f. The duties and responsibilities of employees, independent contractors, and consultants; and (ii) establish a and g. A compliance training program to ensure that RBI for employees and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance lettersindependent contractors. 35. Within ninety (90) days from the effective date of this Agreement, RBI ▇▇▇▇▇▇▇ agrees to submit a draft drafts of its advertisement policies operations and procedures compliance manuals to the Department. 46. Within one hundred twenty (120) days from the effective date of this Agreement, RBI ▇▇▇▇▇▇▇ agrees to submit a copy copies of its final advertisement policies operations and procedures compliance manuals to the Department together with a letter from an authorized officer of RBI Contour indicating his/his or her approval of such policies and proceduressaid manuals. 57. RBI further Contour agrees that its mortgage banking activities will be subject to provide copies of all advertisements run by it examinations semi-annually for the twelve (12) a twenty-four-month period following the effective date execution of this Agreement. 68. RBI Contour agrees to pay a fine of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months. 720,000. RBI Contour further agrees that such payment will be made in immediately available funds in accordance with the Department’s Department payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI Total Group is willing to resolve the violations cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations. Therefore, in consideration of the promises and covenants set forth herein: 1. RBI Total Group agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; andRegulations; b. not conducting or transacting business in this state under any assumed name or designation using any website, domain, or other name that has not been approved by the Superintendent; c. ensuring that its advertisements do not mislead consumers as to the identity of the party offering credit; and c. clearly identifying itself by name and an approved office address located in New York in any advertisement targeted to New York consumers; and d. ensuring that its advertisements do not otherwise mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and e. d. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, clearly and conspicuously all material information. 2. RBI Total Group agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines; (ii) include a listing of all applicable laws, regulations, and truth in advertising guidelines; (iii) establish a mechanism for ensuring that all applicable laws, regulations, and truth in advertising guidelines are met; and (iiiv) establish a training program to ensure that RBI Total Group and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letterstruth in advertising guidelines. 3. Within ninety (90) days from the effective date of this Agreement, RBI Total Group agrees to submit a draft of its advertisement policies and procedures to the Department. 4. Within one hundred twenty thirty (12030) days of receipt of non-objection or any comments from the effective date Department, and after incorporation and adoption of this Agreementall comments, RBI Total Group agrees to submit a copy of its final advertisement policies and procedures to the Department together with a letter from an authorized officer of RBI Total Group indicating his/her approval of such advertisement policies and procedures. 5. RBI Total Group further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 6. RBI Total Group agrees to pay a fine of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months5,000. 7. RBI Total Group further agrees that such payment will be made in immediately available funds in accordance with the Department’s payment instructions.

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI GRI is willing to resolve the violations cited alleged herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violations. Therefore, in consideration of the promises and covenants set forth herein: 1. RBI GRI agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; and; b. ensuring that its advertisements do it will not mislead consumers as utilize an unauthorized domain name or website to the identity of the party offering credit; andconduct New York regulated residential mortgage loan business; c. clearly identifying itself not conducting or transacting business in this state under any assumed name or designation using any website, domain, or other name that has not been approved by name and an approved office address located in New York in any advertisement targeted to New York consumers; andthe Superintendent; d. ensuring that its advertisements do not otherwise mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and e. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, clearly and conspicuously all material information. 2. RBI GRI agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements requirements, and guidance lettersguidelines. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters; and (ii) establish a training program to ensure that RBI and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letters. 3. Within ninety (90) days from the effective date of this Agreement, RBI agrees to submit a draft of its advertisement policies and procedures to the Department. 4. Within one hundred twenty (120) days from the effective date of this Agreement, RBI agrees to submit a copy of its final advertisement policies and procedures to the Department together with a letter from an authorized officer of RBI indicating his/her approval of such policies and procedures. 5. RBI further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 6. RBI agrees to pay a fine of $ 7,500 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreementrequirements, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months. 7. RBI further agrees that such payment will be made in immediately available funds in accordance with the Department’s payment instructions.guidelines;

SETTLEMENT TERMS AND CONDITIONS. Without admitting or denying the Department’s findings, RBI the Applicant is willing to resolve the violations cited herein by entering into this Agreement and freely and voluntarily waives its right to a hearing under Banking Law Sections 44 and 598 on such violationsAgreement. Therefore, in consideration of the promises and covenants set forth herein: 1. RBI The Applicant agrees to take all necessary steps to ensure its compliance with all applicable federal and state laws, regulations, and supervisory requirements relating to its mortgage business, including, but not limited to: a. complying with the requirements of Article 12-D of the Banking Law, and Part 38 of the General Regulations of the Banking Board; and b. ensuring that it will submit an application and receive approval from the Department prior to utilizing any domain name and websites to conduct regulated mortgage loan origination activity; and c. ensuring that it will not activate any websites prior to receiving approval from the Department; and d. ensuring that its advertisements do not mislead consumers as to whether the identity Applicant can fund a mortgage loan or make a mortgage loan; e. ensuring that it does not enter into an employment or otherwise engage any employee or independent contractor who has an employment or independent contractor relationship with any other mortgage banker, mortgage broker or exempt organization without the written approval of the party offering creditSuperintendent; and c. clearly identifying itself by name and an approved office address located in New York in any advertisement targeted to New York consumers; and d. f. ensuring that its advertisements do not mislead consumers as to the terms and conditions of credit it is offering and that such advertisements disclose clearly and conspicuously the existence of material terms, conditions, and limitations relating to any advertised offer of credit; and e. g. ensuring that it will not advertise terms of credit using footnotes, asterisks, small print and color contrasts that materially contradict or modify the principal message of its advertisements, and will disclose clearly, and conspicuously all material information. 2. RBI The Applicant agrees to develop appropriate written advertisement policies and procedures designed to ensure compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters. The policies and procedures shall, at a minimum: (i) designate an individual responsible for monitoring compliance with all applicable federal and state laws, regulations, supervisory requirements and guidance letters; and (ii) establish a training program to ensure that RBI the Applicant and its employees involved in preparing or approving advertisements understand all applicable federal and state laws, regulations, supervisory requirements and guidance letters. 3. Within ninety (90) days from the effective date of this Agreement, RBI the Applicant agrees to submit a draft of its advertisement policies and procedures to the Department. 4. Within one hundred twenty (120) days from the effective date of this Agreement, RBI the Applicant agrees to submit a copy of its final advertisement policies and procedures to the Department together with a letter from an authorized officer of RBI the Applicant indicating his/her approval of such policies and procedures. 5. RBI The Applicant further agrees to provide copies of all advertisements run by it for the twelve (12) month period following the effective date of this Agreement. 6. RBI The Applicant agrees to pay a fine of $ 7,500 10,000 payable in ten (10) equal monthly installments as follows: $750 upon execution of this Agreement, and $750 each on or before the 15th day of each consecutive month for the following nine (9) months. 7. RBI The Applicant further agrees that such payment will be made in immediately available funds in accordance with the Department’s payment instructions.