Cliffside Investors, LLC Order for Unlicensed Mortgage Lending

. 4. Cliffside is not licensed as a Mortgage Lender. 5. Cliffside closed Pennsylvania loans as a Mortgage Lender when it was not licensed as Mortgage Lender. 6. Cliffside cooperated with the Department regarding the matters addressed in this Order. Unlicensed Activity 7. Section 6111(a) of the MLA requires a person engaged in the mortgage loan business as a mortgage lender to be licensed as a mortgage lender. 7 Pa. C.S. § 6111(a). 8. Section 6102 of the MLA defines “mortgage loan business” as “(1) advertising, causing to be advertised, soliciting, negotiating or arranging in the ordinary course of business or offering to make or making mortgage loans, or (2) servicing mortgage loans.” 7 Pa. C.S. § 6102. 9. Section 6102 of the MLA defines “mortgage lender” as “A person who engages in the mortgage loan business by directly or indirectly originating and closing mortgage loans with its own funds in the primary market for consideration.” 7 Pa. C.S. § 6102. 10. Cliffside originated and closed Pennsylvania mortgage loans while not licensed to do so. Authority of the Department 11. The Department has the authority to issue orders as may be necessary for the proper conduct of the mortgage loan business by licensees and the enforcement of the MLA. 7 Pa. C.S. § 6138(a)(4). 12. The Department may fine a person, whether licensed or subject to the provisions of this chapter and not licensed, who violates the act or commits any action which would subject

the licensee to suspension, revocation or nonrenewal under Section 6139 up to $10,000 per offense. 7 Pa. C.S. § 6140(a) and (b). VIOLATIONS 13. Cliffside violated the MLA when it engaged in the business of a mortgage lender while not licensed as a mortgage lender. 7 Pa. C.S. § 6111(a). RELIEF 14. Fine. Cliffside agrees to pay a fine of $2,500 (two thousand five hundred dollars), due within thirty (30) days of the Effective Date of the Order and shall be made through the Department’s secure portal at https://www.portal.dobs.pa.gov. 15. Corrective Action. Within One Hundred Twenty (120) days of the Effective Date of the Order, Cliffside will transfer the Pennsylvania loans closed in their name in violation, to be closed in the name of a licensed Pennsylvania Mortgage Lender or exempt entity and will provide documentation to the Department. FURTHER PROVISIONS 16. Consent. Cliffside hereby knowingly, willingly, voluntarily, and irrevocably consents to the entry of this Order pursuant to the Department’s order authority under the MLA and agrees that it understands all of the terms and conditions contained herein. Cliffside, by voluntarily entering into this Order, waives any right to a hearing or appeal concerning the terms, conditions and/or penalties set forth in this Order. 17. Consumer’s Rights. This Order shall not limit or impair a consumer’s rights under the MLA. 18. Publication. The Department will publish this Order pursuant to its authority in

Section 302.A(5) of the Department of Banking and Securities Code. 71 P.S. § 733-302.A.(5). 19. Entire Agreement. This Order contains the whole agreement between the parties. There are no other terms, obligations, covenants, representations, statements, conditions, or otherwise, of any kind whatsoever concerning this Order. This Order may be amended in writing by mutual agreement by the Office and Cliffside. 20. Binding Nature. The Department, Cliffside, and all officers, owners, directors, employees, heirs and assigns of Cliffside intend to be and are legally bound by the terms of this Order. 21. Counsel. This Order is subject to review by the Department’s Legal Division. This Order is entered into by parties upon full opportunity for legal advice from legal counsel. 22. Effectiveness. Cliffside hereby stipulates and agrees that the Order shall become effective on the date that the Department’s Legal Division dockets this Order (“Effective Date”). 23. Other Enforcement Action. a. The Department reserves all of its rights, duties, and authority to enforce all statutes, rules and regulations under its jurisdiction against Cliffside in the future regarding all matters not resolved by this Order. b. Cliffside acknowledges and agrees that this Order is only binding upon the Department and not any other local, state or federal agency, department or office regarding matters within this Order. 24. Authorization. The parties below are authorized to execute this order and legally bind their respective parties. 25. Counterparts. This Order may be executed in separate counterparts and by facsimile or electronic format.