Willamette Valley Bank pays $425,000 penalty

The FDIC determined the bank had violated the following:

• Section 8(a) of the Real Estate Settlement Procedures Act (“RESPA”), 12 U.S.C. § 2607(a), and 12 C.F.R. § 1024.14(b), by entering into mortgage lead generation arrangements with the operator of a real estate website and the operator of an online loan marketplace that were used to facilitate and disguise referral payments for mortgage business;
• Section 5 of the Federal Trade Commission Act (“Section 5”), 15 U.S.C. § 45(a)(1), by making deceptive and misleading representations in three of the Bank’s prescreened offers of credit; and
• Section 604(f) of the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681b(f), by obtaining the consumer reports of former loan clients with recent credit inquiries without a legally permissible purpose.