- Provide full disclosure regarding interest rates, discount points, prepayment penalties, and other loan or refinancing terms. The agreement provides for both written and oral disclosures.
- Ensure that employees do not defeat the purpose of these disclosures by criticizing or playing down the accuracy or importance of the disclosures.
- Provide the same interest rates and discount points for similarly-situated consumers.
- Ensure that every loan benefits not only Ameriquest and its commissioned employees but the borrower as well.
- Substantially revise their employee compensation system to eliminatecertain incentives. This new system may not provide incentives to include prepayment penalties or any other fees or charges in the mortgages.
- Retrain their employees to comply with the terms of the settlement agreement.
- Monitor their employees more closely to ensure they comply with the settlement agreement.
- Overhaul the company’s appraisal practices by removing branch offices and sales personnel from the appraiser selection process, prohibiting them from pressuring appraisers for higher values and instituting a system of periodic review to ensure the independence of appraisers and the accuracy and integrity of the appraisals.
- Limit prepayment penalty periods on certain variable rate mortgages.
- Not solicit their borrowers to refinance during the first 24 months of their loan, unless the borrower initiates it.
- Use independent loan closers.
- Adopt policies to protect whistle-blowers and facilitate reporting of improper conduct.