Certified Forensic Loan Auditors, LLC, Andrew Lehman, and Michael Carrigan
On September 6, 2019, the Consumer Financial Protection Bureau (Bureau) filed a complaint in federal court in the Central District of California against Certified Forensic Loan Auditors, LLC (CFLA), Andrew Lehman (Lehman), and Michael Carrigan (Carrigan). CFLA is a foreclosure relief services company incorporated in California and Texas and headquartered near Houston, Texas. Lehman is CFLA’s president and CEO, and Carrigan was the Company’s sole auditor. The complaint, which the Bureau amended in November 2019, alleged that CFLA and Lehman engaged in deceptive and abusive acts and practices in violation of the Consumer Financial Protection Act and charged unlawful advance fees in connection with the marketing and sale of financial advisory and mortgage assistance relief services to consumers in violation of Regulation O and the CFPA. The amended complaint further alleged that Carrigan provided substantial assistance to CFLA and Lehman.
Concurrent with the filing of the initial complaint, the Bureau and Carrigan filed a proposed stipulated final judgment and order to resolve the Bureau’s claim against Carrigan, which the court entered on October 29, 2019. It bans Carrigan from providing mortgage assistance relief services or consumer financial products and services and imposes a $493,000 civil money penalty, all but $5,000 of which is suspended based on his limited ability to pay more based on sworn financial statements. On July 20, 2020, the Court entered a stipulated final judgment resolving the Bureau’s claims against the remaining defendants, CFLA and Lehman. Under the order, CFLA and Lehman are permanently banned from providing mortgage assistance relief services or financial advisory services. The order imposes a suspended judgment against CFLA and Lehman for redress of $3 million and imposes a civil money penalty of $40,000.