One thing lenders often overlook is the manner in which potentially isolated compliance problems can in retrospect be weaved into an elaborate and intentional conspiracy. An example is the Amerisave consent decree, entered into last week. The lender was accused of bait and switch marketing — advertising lower payments and rates than were actually available to borrowers. Further, the company allegedly failed to give affiliated business disclosures in a timely manner and had borrowers provide payment authorization for appraisals before the GFE and other disclosures were delivered. The result was a $19.5 million settlement, which included a $4.5 million corporate penalty and a $1.5 million penalty personally levied against a corporate executive.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide.
Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.