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Consumer Financial Protection Bureau Sues 1st Alliance Lending, LLC and Its Principals for Alleged Unlawful Mortgage Lending Practices

WASHINGTON, D.C. — Today, the Consumer Financial Protection Bureau (Bureau) filed a lawsuit against 1st Alliance Lending, LLC, John Christopher DiIorio, Kevin Robert St. Lawrence, and Socrates Aramburu for allegedly engaging in various unlawful mortgage-lending practices. 1st Alliance, based in Hartford, Connecticut, originated residential mortgages from 2004 to September 2019 and stopped operating in November 2019. DiIorio was its chief executive officer and he, St. Lawrence, and Aramburu were 1st Alliance’s three managing executives. The Bureau alleges that 1st Alliance, with DiIorio’s, St. Lawrence’s, and Aramburu’s participation, knowledge, and direction, violated the Truth in Lending Act (TILA), the Fair Credit Reporting Act (FCRA), the Equal Credit Opportunity Act (ECOA), the Mortgage Acts and Practices—Advertising Rule (MAP Rule), and the Consumer Financial Protection Act of 2010 (CFPA). The Bureau’s complaint, which was filed in the United States District Court for the District of Connecticut, seeks injunctions against the defendants, as well as damages, redress to consumers, disgorgement of ill-gotten gains, and the imposition of civil money penalties.

The Bureau alleges that since at least 2015, in the course of its mortgage-lending business, 1st Alliance used unlicensed employees to engage in mortgage-origination activities and interactions with consumers that required them to be licensed under state law, in violation of TILA and Regulation Z, its implementing regulation. The Bureau further alleges that 1st Alliance’s use of unqualified sales employees to deprive consumers of critical, accurate, and timely loan information was unfair. The Bureau also alleges that 1st Alliance violated Regulation Z by requiring consumers to submit documents verifying information relating to the consumer’s residential-mortgage-loan application before providing them a Loan Estimate.

The Bureau alleges that during this same period, 1st Alliance employees denied credit to consumers based on information in their consumer report or in response to their application but did not give consumers the “adverse action” notice required under FCRA and ECOA. The Bureau also alleges that 1st Alliance representatives repeatedly engaged in misleading representations, omissions, or practices toward consumers. These included misrepresentations, omissions, or practices concerning whether 1st Alliance’s employees were licensed mortgage-loan originators, whether the consumer had been preapproved or guaranteed for a particular program or term, and whether and on what terms the consumer was likely to obtain refinancing, in violation of the MAP Rule and CFPA.

The complaint is not a finding or ruling that the defendants have violated the law.

A copy of the complaint filed in federal district court in the District of Connecticut is available at: https://files.consumerfinance.gov/f/documents/cfpb_1st-alliance-lending-llc-et-al_complaint_2021-01.pdf

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The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and by empowering consumers to take more control over their economic lives. For more information, visit www.consumerfinance.gov.