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2014-CFPB-0002 Document 205 Filed 11/25/2014 Page 1 of 105 2014-CFPB-0002 Document 205 Filed 11/25/2014 Page 1 of 105 UNITED STATES OF AMERICA Before the CONSUMER FINANCIAL PROTECTION BUREAU November 25, 2014 ADMINISTRATIVE PROCEEDING File No. 2014-CFPB-0002 In the Matter of PHH CORPORATION, RECOMMENDED DECISION PHH MORTGAGE CORPORATION, (PUBLIC VERSION) PHH HOME LOANS LLC, ATRIUM INSURANCE CORPORATION, and ATRIUM REINSURANCE CORPORATION APPEARANCES: Lucy Morris, Cara Petersen, Sarah J. Auchterlonie, Donald R. Gordon, Kimberly J. Ravener, Navid Vazire, and Thomas Kim representing the Office of Enforcement, Consumer Financial Protection Bureau Mitchel H. Kider, David M. Souders, Sandra B. Vipond, Leslie A. Sowers, Rosanne L. Rust, and Michael S. Trabon, Weiner Brodsky Kider PC, representing Respondents BEFORE: Cameron Elliot, Administrative Law Judge, Securities and Exchange Commission SUMMARY This Recommended Decision (RD) finds that Respondents PHH Corporation, PHH Mortgage Corporation (PHH Mortgage), PHH Home Loans LLC (PHH Home Loans), Atrium Insurance Corporation (Atrium Insurance), and Atrium Reinsurance Corporation (Atrium Re) (collectively, PHH or Respondents) accepted reinsurance premiums in violation of Sections 8(a) and 8(b) of the Real Estate Settlement Procedures Act (RESPA). The RD recommends imposition of an injunction and disgorgement of $6,442,399 as to all Respondents jointly and severally. 2014-CFPB-0002 Document 205 Filed 11/25/2014 Page 2 of 105 TABLE OF CONTENTS I. INTRODUCTION ...................................................................................................................... 1 A. Procedural Background ............................................................................................................ 1 B. Summary of Allegations ........................................................................................................... 1 C. Official Notice .......................................................................................................................... 2 II. FINDINGS OF FACT ................................................................................................................ 3 A. Respondents ............................................................................................................................. 3 B. Industry Developments Before 2001 ........................................................................................ 5 C. Atrium Starts its First Captive .................................................................................................. 7 D. Atrium’s Later Captive Arrangements ..................................................................................... 8 E. Atrium Carves Out Subprime Loans From Reinsurance Coverage ....................................... 11 F. 2006: Request for Proposal ................................................................................................... 13 1. Radian .............................................................................................................................. 17 2. UGI .................................................................................................................................. 18 G. 2008: Freddie Mac Changes its Reinsurance Policy ............................................................. 20 H. UGI Amends its Captive Arrangement and Regains PHH Business ..................................... 25 I. Atrium’s Captive Arrangement with Genworth Ends ............................................................ 28 J. Atrium’s Captive Arrangement with Radian Ends................................................................. 29 K. Atrium’s Captive Arrangement with CMG Ends ................................................................... 30 L. Developments Since 2009 ...................................................................................................... 31 M. Summary Witness for Enforcement .................................................................................... 35 N. The HUD Letter and Milliman ............................................................................................... 39 O. Experts .................................................................................................................................... 49 1. Mark Crawshaw ............................................................................................................... 49 2. Michael Cascio ................................................................................................................. 50 3. Vincent Robert Burke ...................................................................................................... 50 4. Expert Opinions Regarding Risk Transfer ....................................................................... 51 a. 10/10 Test ..................................................................................................................... 51 b. FAS 113 ........................................................................................................................ 52 c. Prospective vs. Retrospective Analysis ........................................................................ 53 d. Single Book Year vs. Multiple Book Year Analysis.................................................... 53 ii 2014-CFPB-0002 Document 205 Filed 11/25/2014 Page 3 of 105 e. Structure of the Captive Trusts ..................................................................................... 57 f. Funding of the Captive Trusts .......................................................................................... 57 g. Whether Atrium’s Liability was Limited to the Trusts ................................................ 57 h. Purpose of Captive Arrangements ................................................................................ 59 i. Dividends and Commutations ......................................................................................... 61 j. Reliability of Milliman’s Reports .................................................................................... 62 5. Expert Opinions Regarding Price Commensurability ...................................................... 62 III. DISCUSSION AND CONCLUSIONS OF LAW .............................................................. 63 A. Atrium’s Captive Arrangements Did Not Meet the Requirements of the HUD Letter .......... 63 1. Some Book Years Exhibited Risk Transfer ..................................................................... 64 2. Respondents Did Not Prove Price Commensurability ..................................................... 67 B. RESPA Section 8 ................................................................................................................... 70 1. Respondents Violated RESPA Sections 8(a) and 8(b) .................................................... 70 2. Respondents Violated RESPA After July 20, 2008 ......................................................... 73 3. Respondents Do Not Qualify for RESPA’s Section 8(c)(2) Safe Harbor ....................... 75 4. Defense of Satisfaction of the HUD Letter Test and Factors Is Unavailing .................... 77 C. Judicial Estoppel .................................................................................................................... 78 D. Jurisdiction Over Atrium and Atrium Re ............................................................................... 82 E. McCarran-Ferguson Act ......................................................................................................... 82 IV. SANCTIONS AND RELIEF ............................................................................................... 83 A. Joint and Several Liability ...................................................................................................... 83 B. Disgorgement ......................................................................................................................... 84 1. Legal Standard ................................................................................................................. 84 2. Offsets and Calculation .................................................................................................... 88 C. Civil Money Penalties ............................................................................................................ 94 D. Injunction ............................................................................................................................... 94 1. Cease and Desist Order .................................................................................................... 94 2. Captive Reinsurance Bar .................................................................................................. 98 3. Disclosure Order ............................................................................................................ 101 V. PROPOSED ORDER ............................................................................................................. 102 iii 2014-CFPB-0002 Document 205 Filed 11/25/2014 Page 4 of 105 I. INTRODUCTION A. Procedural Background On January 29, 2014, the Consumer Financial Protection Bureau (Bureau) filed a Notice of Charges Seeking Disgorgement, Other Equitable Relief, and Civil Money Penalty (Notice of Charges or Notice) against Respondents. PHH Corporation, 2014-CFPB-002, Document 1.1 On January 31, 2014, Respondents filed their Answer and Affirmative Defenses (Answer) and a Motion to Dismiss the Notice of Charges or, in the Alternative, for Summary Disposition.
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