Greentree Mortgage Company
Mortgage company Greentreeorg.uk/register/) under number 440718. The Greentree Financial Planning Ltd is incorporated in England and Wales under the number 09489587.
membership detail
Everyone looking to re-finance or buy a house. Brokers, CPA's, or anyone else who wants to buy or fund a house. Tu, 02. October 2018 Do you enter information in Connect correctly and in good time? You are a member of the leadership team of your section and are responsible for inputting people?
From Cincinnati, Ohio's Friends in Business Chapters, Sally Waxman, of Cincinnati, Ohio, October 02, 2018, strengthens the BNI Member Network's credibility with a look at her own BNI story. Dr. Misner described how his childhood instructors all had the same complaint: That which his teacher saw as a bottleneck turned out to be an asset.
section members
Tu, 02. October 2018 Do you enter information in Connect correctly and in good time? You are a member of the leadership team of your section and are responsible for inputting people? From Cincinnati, Ohio's Friends in Business Chapters, Sally Waxman, of Cincinnati, Ohio, October 02, 2018, strengthens the BNI Member Network's credibility with a look at her own BNI story.
Dr. Misner described how his childhood instructors all had the same complaint: That which his teacher saw as a bottleneck turned out to be an asset.
The Federal Trade Commission und Consumer Financial Protection Bureau v. Green Tree Servicing LLC (FTC)
The Financial Consumer Protection Bureau (the "CFPB") and the Federal Trade Commission (the "FTC" and together with the CFPB the "Agencies") on 21 April 2015 jointly launched a set of execution measures against Green Tree Servicing LLC ("Green Tree").
The authorities claim in their complaints (the "Complaint") and the suggested Common Order (the "Common Order" and, together with the complaints, the "Green Tree Action") that Green Tree has committed a number of dishonest or misleading actions or practises that violate the Federal Trade Commission Act (the "FTC Act"),
and the Consumer Financial Protection Act (the "CFP Act"),3 as well as practices that violate the Fair Debt Collection Practices Act,4 the Fair Credit Reporting Act,5 and the Real Estate Settlement Procedures Act. In particular, the agencies claim that Green Tree did not take into account changes to credits provided by other service providers and did not participate in other instances of malpractice with regard to overdue debt.
Green Tree is remarkable for two main reason. Firstly, it seems to be the first measure under which the CFPB has acted under the FTC's long-standing'justification doctrine', which obliges the advertiser (or, in this case, the consumer's debtor) to'obtain a justification''for a demand (express or implied) made to a customer at the moment of assertion so that the demand is not 'misleading'.
Secondly, the Green Tree action seems to be the first common operation between the CFPB and the FTC, which could represent an important evolution in the relations between the agencies, which have special powers to prosecute dishonest or misleading actions or practice. And the Green Tree Campaign also confirmed that agencies continue to focus on mortgage abuse.
Clause 5(a) of the FTC Act9 forbids "unfair or fraudulent conduct or conduct in or affecting trade", while Clauses 1031 and 1036(a)(1)(B) of the CFP Act10 forbid data subjects from engaged in "unfair, fraudulent or improper conduct or conduct". In general, an act or conduct is considered deceptive if it deceives or is likely to deceive a customer, the customer's understanding is appropriate in the particular circumstance and the act or conduct is manifest.
Misrepresentation or misleading omission of essential facts are deemed to be misleading actions or practice. Activities or practice are dishonest if they cause significant harm to the consumer which the consumer cannot reasonably prevent and which is not offset by contrary consumer or competitive advantages. For the Green Tree Action, the CFPB seems to have trusted its power under the CFP Act to prosecute'misleading' and'unfair' (but not'abusive') actions or practice.
Green Tree, as a mortgage provider, concludes agreements with mortgage providers on the right to operate the mortgage for a charge. Services provided range from preparing and mailing one-month invoices to borrower, collection of payment, handling of payment, securing proper insurance of the pledged object and handling of real estate taxes. Both the Complaint and the Order maintain that Green Tree has committed the following unlawful or misleading actions or practises in breach of the FTC Act and the CFP Act:
make inaccurate or ''unfounded'' statements to the consumer that consumers' mortgage credits had certain outstanding balance, due date, interest rate, interest rate, amount of payments per month, status of arrears and charges or other amount due (collectively the''loan data''); represent that the consumer would have to make a repayment on their credit before Green Tree would consider them for credit amendment if such repayment was not necessary or legally permissible; fail to investigate in a timely fashion and react to consumers' applications for shortages;
declare to the consumer that non-payment of a mortgage credit would lead to the detention or detention of the consumer or to the confiscation, execution, attachment of, or selling of the consumer's goods or salaries, if such non-payment had not led to such measures; The FTC has long argued that an advertisers under Section 5 of the FTC Act must have a "reasonable basis" for explicit or implicit entitlements that make unbiased statements about an object or services promoted so that the entitlement is not deemed "misleading".
In the complaint, the agencies claim that Green Tree's statements to the consumer regarding credit data were incorrect on a number of occasions or " unfounded " at the point of the statements. Presentations to individuals in the Green Tree case about their own credits differ significantly from advertisements to a wide public involving classical FTC cases.
It is therefore by no means certain that the use of CFPB terms in a common operation with the FTC will create a new context for the consumer orientation of exposures from banks. Accordingly, the Green Tree Action poses important issues for banks that base their interaction with the consumer - to recover debts or otherwise - on information gathered or collated by third partys.
Related topics are presented to debtors and other services suppliers who depend on a bank's recording system to interact with them. Widespread application of the doctrine may require banks to better document the foundation of all consumer exposures they make before recourse is made in order to have an appropriate compliant governance system.
This Green Tree Act seems to be the first case in which the FTC and CFPB have taken common measures since the creation of CFPB in 2011. Green Tree is part of a move towards greater collaboration between the two companies. In 2012, the FTC and CFPB jointly reviewed the advertising of mortgage lending, refinancing and inverted mortgage lending to detect imprecise or deceptive conveyances and deceptive claims about the cost of inverted mortgage lending.
In February 2015, CFPB made the announcement under this scheme that it would take legal actions against three mortgage banks that claimed to have deceived the consumer by alleging that the US administration had authorised their product. The FTC, although part of the collective investigation of such complaints, did not take part in the enforcing measure.
Whether the agencies' collaboration and co-involvement in the Green Tree Action is part of a wider drive to harmonise the two agencies' implementation measures is not clear, or whether their work has been pooled in reaction to Green Tree's own particular practice. It is important that the Green Tree Action provides further proof of a wider tendency for regulators to take concurrent, concomitant, cascading and probably additives measures to take a stance on the same issue.