RESPA Violations: Inconsistent Enforcement

QUESTION 

I am the General Counsel and Compliance Officer of a mortgage lender in the Northeast. We originate retail and wholesale loans and are licensed in all states and territories. Recently, we had a multistate banking audit. The audit found that some of our Third-Party Originators (TPOs) had violated RESPA. 

After conducting a servicing quality control audit, we have decided to sue several TPOs for causing these RESPA violations. The problem we’re having is that RESPA does not address its enforcement consistently or comprehensively. It provides specific penalties in some sections but fails to mention remedies for violations in other sections. 

I want some guidance in navigating RESPA’s maze to determine where a private right of action is available and where it isn’t. In particular, I need some advice on how the TRID rule affected RESPA enforcement and private causes of action. 

COMPLIANCE SOLUTIONS 

Servicing Quality Control Audits 

Servicing Tune-up® 

Servicing Compliance 

ANSWER 

The Dodd-Frank Wall Street Reform (Dodd-Frank) and Consumer Protection Act (CPA) may have altered your scenario somewhat. Although courts generally have failed to examine this issue thoroughly, it is important to note that courts have given Chevron deference to the CFPB’s analysis of the topic. However, that approach may be about to change in light of Chevron's demise,[i] which I will discuss a bit below. 

If you’re using outside counsel for this litigation, be sure to retain a firm that has extensive experience in such matters. You can contact me here to discuss a referral. 

I will give you a brief overview with an emphasis on the TILA-RESPA Disclosure Integration Rule (TRID Rule). Let’s first talk history! 

RESPA PENALTIES 

The Real Estate Settlement Procedures Act (RESPA) contains penalty provisions for Section 6, which deals with mortgage servicing and escrow administration);[ii] Section 8, which prohibits kickbacks and unearned fees);[iii] Section 9, which deals with title companies;[iv] and the escrow statement requirements of Section 10.[v] 

RESPA does not include penalties for violations of other sections, such as Section 4 (HUD-1 Settlement Statements), Section 5 (Special Information Booklets and Good Faith Estimates), Section 10 (Limitations on Escrow Accounts), and Section 12 (Fees for Preparation of Truth-in-Lending or Settlement Statements). However, the absence of RESPA penalty provisions may no longer afford defendants the comfort it once did. 

RESPA’s HANDOFF TO TILA 

The TRID Rule, adopted in November 2013, and effective October 3, 2015, introduced another twist to RESPA enforcement. As just stated, RESPA does not provide private rights of action for violations of Sections 4 and 5, the sections regarding Good Faith Estimates and Settlement Statements. The TRID Rule extrapolated some of the RESPA Section 4 and 5 requirements that had previously appeared in Regulation X (implementing RESPA) over to Regulation Z (implementing TILA, the Truth in Lending Act). 

A HISTORY LESSON 

This transmogrification of RESPA Sections 4 and 5 had the effect of expanding RESPA liability by bringing those provisions into the purview of the TILA – and TILA provides for a private right of action. You might think of it as legal and regulatory prestidigitation! 

Now, there was considerable pushback to this switcheroo. One of the biggest gripes was that the TRID Rule would invite consumers to bring lawsuits seeking TILA remedies for RESPA violations. The upshot of this concern was to have the Consumer Financial Protection Bureau (CFPB or Bureau) specify which provisions of Regulation Z, as affected by the TRID Rule, relate to TILA requirements and which relate to RESPA requirements.[vi] 

The CFPB awkwardly responded in this way: 

“While the final regulations and official interpretations do not specify which provisions relate to TILA requirements and which relate to RESPA requirements, the section-by-section analysis of the final rule contains a detailed discussion of the statutory authority for each of the integrated disclosure provision.” 

And, having side-stepped a formal resolution, the 

“… detailed discussions of the statutory authority for each of the integrated disclosure provisions [in the section-by-section analysis] provide sufficient guidance for industry, consumers, and the courts regarding the liability issues raised by the commenters.” 

Obviously, this was hardly a satisfying response. Nevertheless, industry participants implemented the TRID Rule while still expressing considerable concern about the CFPB's choice to fit the changes into Regulation Z. The apprehension stemmed from the fact that TILA and Regulation Z impose substantial liability for disclosure violations, compared to the general lack of liability under RESPA and its implementing Regulation X. 

THE CFPB’S SOLOMONIC DECISION 

The CFPB chose to exclude most closed-end consumer credit transactions secured by real property, other than reverse mortgages, from the early disclosure requirements of Regulation Z[vii] and the standard closed-end disclosure requirements of Regulation Z.[viii] In place of those requirements, the CFPB’s TRID Rule created three sets of provisions for the partially-excluded loans: 

1.     Loan Estimate. 

2.     Closing Disclosure. 

3.     Special Information Booklet. 

This partial exclusion of TRID Rule transactions from certain Regulation Z provisions leaves the rest of Regulation Z in effect for those transactions, as previously applied.[ix]

Conversely, the CFPB fit the TRID changes into the RESPA regime by excluding the loans covered by the TRID Rule from five provisions of RESPA Regulation X: 

·       Special Information Booklet. Regulation X § 1024.6. For loans subject to the TRID Rule, Regulation Z § 1026.19(g) imposes the same Special Information Booklet requirement. 

·       Good Faith Estimate. Regulation X § 1024.7. For loans subject to the TRID Rule, Regulation Z § 1026.19(e) imposes the Loan Estimate requirement. 

·       HUD-1/1A Settlement Statement. Regulation X § 1024.8. For loans subject to the TRID Rule, Regulation Z § 1026.19(f) imposes the Closing Disclosure requirement. 

·       HUD-1/1A Administration. Regulation X § 1024.10, one day advance inspection of HUD-1/1A Settlement Statement, delivery, and recordkeeping requirements. For loans subject to the TRID Rule, Regulation Z §§ 1026.19(e) and (f) impose corresponding requirements for Loan Estimates and Closing Disclosures. 

·       Servicing Transfer Application Disclosure. Regulation X § 1024.33(a). For loans subject to the TRID Rule, Regulation Z § 1026.37(m)(6) requires a corresponding disclosure on page three of the Loan Estimate. 

In general, the TRID Rule leaves these provisions of Regulation X in place for the loans not subject to TRID, that is, reverse mortgages and the few federally related mortgage loans made by creditors not subject to Regulation Z (i.e., lenders who make five or fewer mortgage loans per calendar year secured by dwellings, unless they make more than one High Cost Mortgage  (HCM)). All of the other provisions of Regulation X remain in place for federally related mortgage loans, including those subject to the TRID Rule. 

GOOD LUCK WITH THAT! 

A careful consideration of the CFPB’s detailed discussion in its section-by-section analysis of the TRID Rule suggests that the agency’s response can be summarized as follows: 

Bona Fortuna in separating disclosure liability between TILA and RESPA! 

Take a deep breath and consider this off-the-cuff outline of the TRID disclosures in the context of the statutory framework for each disclosure item through the lens of the following cascade: 

1.     Any prior implementation of that requirement,

2.     The CFPB’s research into the effectiveness of that disclosure from both a consumer and industry perspective,

3.     The Bureau’s alteration (if applicable) of the statutory requirement or previous regulatory implementation of the requirement to respond to its research,

4.     The Bureau’s agency’s reasons for implementing that disclosure as part of TILA-RESPA disclosure integration, and

5.     The statutory support for including the final version of the disclosure. 

And that’s just for starters! 

In most cases, the ultimate statutory support rested on a specific requirement stated in TILA, RESPA, and/or the Dodd-Frank Act, bolstered by the regulatory flexibility offered in TILA § 105(a) (sometimes also § 105(f)), RESPA § 19(a), and Dodd-Frank Act §§ 1032(a) and 1405(b). 

The CFPB relied on regulatory flexibility given by these provisions because the agency found it necessary to reconcile differences between the RESPA and TILA statutes and between sometimes differing provisions within the TILA statute itself. The agency also found it appropriate to alter many of the statutory requirements (and even discard some) based on conclusions drawn from its research. Consequently, many resulting disclosure items are not derived solely from one statute or the other but from one or more statutory starting points and the broad rulemaking authority given to the CFPB by TILA, RESPA, and the Dodd-Frank Act. Obviously, unraveling the final result to separate a RESPA claim from a TILA claim can be a challenging task. 

So far, most courts have taken the CFPB at its word and relied on its analysis of the TRID Rule (and the 2013 RESPA and TILA Mortgage Servicing Rule) to determine whether a private right of action is available for a regulatory violation. But there has been litigation.[x] And now, after the U.S. Supreme Court’s overruling of the Chevron deference,[xi] I think we’re likely to see courts dive more deeply into this issue.

OBSERVATIONS

As suggested above, the U.S. Supreme Court’s overruling of Chevron deference may require courts to ignore the CFPB’s stated “intentions” and look more closely at the underlying statutory provisions.[xii] 

Conceivably, borrowers might add Dodd-Frank Act claims to their RESPA claims. That is, they might claim that violations of RESPA violate the Dodd-Frank Act. Section 1055 of the Dodd-Frank Act offers the possibility of substantially higher penalties than those specified by RESPA – ranging from $5,000 per day for any violation to $1 million per day for a “knowing violation” (adjusted annually to reflect inflation). Whether an enforcement agency must seek Dodd-Frank penalties or may be obtained by consumers in private actions is an open question courts may someday decide. 

Jonathan Foxx, Ph.D., MBA
Chairman & Managing Director 

Lenders Compliance Group

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[i] Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024)

[ii] 12 USC §§ 2605(d) and 2614

[iii] 12 USC §§ 2607(d) and 2614

[iv] 12 USC §§ 2608(b) and 2614

[v] 12 USC §§ 2609(d)

[vi] Indeed, a rather convoluted view suggested that the CFPB should implement the TILA disclosure requirements in Regulation Z and the RESPA disclosure requirements in Regulation X in order to discourage litigation invoking TILA’s liability scheme for RESPA violations.

[vii] Regulation Z § 1026.19(a)

[viii] Regulation Z § 1026.18

[ix] For example, the Consumer Handbook on Adjustable Rate Mortgages (CHARM) Booklet and ARM Program Disclosure requirements of Regulation Z § 1026.19(b) continue to apply as they did prior to the TRID Rule.

[x] A recent decision by a federal district court in Texas illustrates this issue. Bassett v. PHH Mortgage, 2024 U.S. Dist. (S.D. Tex. June 27, 2024) (magistrate recommendation), approved and case dismissed by 2024 U.S. Dist. (July 16, 2024). Note: This litigation determined, in particular, that 12 U.S.C. §§ 2605(f) and 2614 do not create private causes of action, nor does RESPA provide private causes of action for violations of Regulation X §§ 1024.35 and 1024.39. As support, the court cited several other decisions within its district. The court acknowledged that Regulation X § 1024.41, “unlike the other RESPA provisions at issue…expressly provides for a private right of action.”

[xi] Op. cit. i

[xii] Op. cit. x

Accurate and Reasonable Disclosures

QUESTION

You may feel that our question is unusual. Still, we think it involves concerns that many people have relating to disclosures, particularly how to determine if a disclosure is accurate or inaccurate.

In my experience, this issue comes up a lot. We use document vendors, but we are relying too much on them for accuracy. We found this out the hard way when a regulator found that one of the TILA disclosures was inaccurate and unreasonable.

The idea of accuracy makes sense, but this notion of reasonableness seems pretty subjective to us.

So, we want to know what is considered reasonable in TILA disclosures?

ANSWER

Your question is not as unusual as you may think. Our compliance professionals are often presented with providing guidance on disclosure compliance. We consider several factors, one of which is the reasonableness of the disclosures.

Regulation Z[i] includes several rules regarding disclosures, including the basis on which disclosures must be given, the use of estimates, and the treatment of irregularities.

Here’s a good rule of thumb for you to follow when reviewing a disclosure: it must reflect the terms of the legal obligation between the parties.

For example, suppose a borrower executes an unsecured note that provides for the total debt to be due five years from the date of the loan. In that case, disclosures must be based on the 5-year term, even if the borrower might informally promise to make monthly or quarterly payments of accrued interest. In other words, disclosures must reflect the credit terms to which the parties are legally bound at the outset of the transaction.

Furthermore, under Regulation Z[ii], if any information necessary for an accurate TILA disclosure is unknown to the creditor, the creditor must make the disclosure based on the best information reasonably available and state that the disclosure is an estimate. This provision provides that disclosures may be estimated if the exact information is unknown at the time the disclosures are made. The provision is based on a section of TILA[iii] that authorizes the CFPB to provide by regulation that any portion of the information TILA requires to be disclosed may be given in the form of estimates when the provider of the information is not in a position to know exact information.

Under Regulation Z, a creditor has no liability for an inaccurate disclosure if the necessary information is not reasonably available by the time of consummation. However, even if a disclosure is validly marked as an estimate before consummation, the creditor may still be required to redisclose when more accurate information becomes available by the time of consummation.[iv]

The estimates must be made in good faith, based on the best information reasonably available, and designated as estimates in the segregated disclosures. Under Regulation Z, as to open-end credit[v] and closed-end credit[vi], creditors are required to make disclosures based on the “best information reasonably available” and to state that the disclosure is an estimate when “any information necessary for an accurate disclosure is unknown.”

A case involving a military veteran illustrates the juncture of “best information reasonably available” and when “any information necessary for an accurate disclosure is unknown.” Let’s check it out.

In Pennsylvania, a federal district court recently examined these requirements in light of a lender’s disclosure of property taxes based on an expected exemption for a borrower.[vii] In some states, such as Pennsylvania, a military veteran may be exempted from paying local property taxes under certain circumstances.

Nelson, a retired, 100-percent disabled military veteran, obtained a home mortgage loan from Acre Mortgage. Under a state program, veterans classified as 100-percent disabled could be exempted from paying local property taxes so long as their income fell below a statutory maximum. Although officials made determinations regarding the income-eligibility criteria with the state veterans’ commission, county veterans' offices handled applications for the exemption.

In her loan application, Nelson disclosed a monthly income of $7,086.83, including $1,510 in social security disability benefits, $2,906.83 in non-educational veterans’ benefits, and $2,670 in military pension benefits. She did not disclose any other income, and, at closing, she signed a statement acknowledging the income information to be true and correct.

In conducting its due diligence before closing, Acre Mortgage consulted the county officials to confirm that property taxes could be excluded. Based on Nelson's income information to Acre Mortgage, county officials informed Acre Mortgage that Nelson should be eligible for the property tax exemption. Nelson also had previously spoken with county officials.

One or two days before closing, Acre Mortgage again contacted county officials to confirm Nelson’s eligibility for the tax exemption, and the county informed Acre Mortgage that, based on the income information submitted to the lender, she was eligible, but that the exemption could not be formally granted until Nelson had title to the property. Accordingly, Acre Mortgage excluded property taxes from the loan disclosures and closing documents.

In December 2015, after closing, Nelson applied for the veteran property tax exemption. In February 2016, the state veterans’ commission notified her that she was not eligible for an exemption because she received educational benefits that increased her income above the statutory maximum for eligibility.

Nelson completed a graduate degree program in May 2016 and then no longer received educational veterans’ benefits. Her income fell below the statutory maximum, and in 2017 she was granted the tax-exempt status.

She sued Acre Mortgage, including TILA violations among other claims. She claimed that Acre Mortgage had provided disclosures on the wrong forms (by failing to use the Loan Estimate and Closing Disclosure and instead using Good Faith Estimate and other forms that had preceded the implementation of the Loan Estimate and Closing Disclosure), failed to disclose local property taxes, and failed to make a reasonable and good faith determination of her ability to repay the loan.

The court dismissed her TILA claims. Evidence showed that Nelson had failed to disclose her educational veterans’ benefits as income and further indicated that Acre Mortgage had relied on the representations of both Nelson and county officials regarding her eligibility for the disabled veterans’ property tax exemption. Evidence also showed that Acre Mortgage had acted in good faith and exercised due diligence in seeking to determine whether property taxes could be excluded from her estimated monthly payment and other mortgage loan disclosures.

In addition, evidence showed that Acre Mortgage had based the TILA disclosures on the best information reasonably available at the time the disclosures were provided and had clearly stated that the disclosures were estimates.

Finally, evidence showed that the ability-to-repay determination was based on the best information reasonably available at the time of loan consummation. No reasonable jury could have returned a verdict in favor of Nelson with respect to whether Acre Mortgage had made a reasonable and good faith determination of ability to repay or whether Acre Mortgage had adequately disclosed Nelson’s local property tax obligations or estimated monthly payments.

The court also held that Acre Mortgage had used the proper disclosure forms, as the TRID disclosure forms (viz., Loan Estimate and Closing Disclosure) were not required until after Nelson submitted her loan application.

TRID disclosure requirements took effect for applications received on or after October 3, 2015, but Acre Mortgage received Nelson’s application on September 24, 2015.

Jonathan Foxx, Ph.D., MBA
Chairman & Managing Director 

Lenders Compliance Group

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[i] § 1026.17(c)
[ii] § 1026.17(c)(2)
[iii] TILA § 121(c), 15 U.S.C. § 1631(c)
[iv] As set forth in Regulation Z § 1026.17(f), see “early disclosures when a subsequent event renders them inaccurate.”
[v] §§ 1026.5(c)
[vi] 1026.17(c)(2)
[vii] Nelson v. Acre Mortgage & Finance, Inc., 2020 U.S. Dist. (M.D. Pa. Sept. 25, 2020)

Ordering Appraisals prior to Submission of Application

QUESTION

We are a residential mortgage lender. Customers are asking us if we can order an appraisal prior to their submission of an application to us so that they are sure that the property will appraise sufficiently. We are aware that if a customer orders an appraisal we would not be able to accept it, as it will not be in our name and our investors do not allow for a transfer of the appraisal. We would like to accommodate our customers by offering this service and helping them avoid paying for an appraisal twice.

We envision that we will order the appraisal with the customer paying for the appraisal at the time it is done. The appraisal report will come directly to us as the lender and then we will provide a copy of the appraisal to the customer. If the customer then wants to proceed, we will use the same appraisal to support the loan. Is the foregoing procedure permissible and, if so, are there any risks to proceeding in this manner?

ANSWER

While it is understandable that the customer does not want to pay for an appraisal twice and you as the lender want to accommodate your customers,  for the reasons set forth below, it is recommended that a lender does not order the appraisal prior to issuing initial disclosures and obtaining an intent to proceed. Your scenario is fraught with RESPA, Fair Lending and UDAAP implications.

You state that the potential applicant will pay for the appraisal “at the time it is done”. If the idea is that the customer will pay the appraiser directly at the time he does the appraisal, and if the appraisal is to be later used to support the loan, this is not permissible. Appraiser Independence requirements do not permit an appraiser to collect payment directly from the borrower. The lender or its designated third party must select, retain, and provide for all compensation to the appraiser. So, if the appraisal is to be used in the loan origination process, the lender must be the party that orders the appraisal and pays for same.

Similarly, it is not permissible for the customer is to pay the lender upfront with the lender remitting payment to the appraiser, as this scenario constitutes a RESPA violation. In order to collect payment from the applicant, the lender must charge the applicant the cost of the appraisal. Under RESPA, a lender, cannot charge a potential loan applicant any fee, including an appraisal fee, prior to issuing the GFE and the applicant indicating an intent to proceed. Although RESPA does not prevent a lender from ordering the appraisal prior to the issuance of the GFE and receipt of an intent to proceed, in the event the potential applicant does not proceed with an application or the transaction does not close, the lender runs the risk it will not be able to seek reimbursement from the potential applicant.

Even if the lender is willing to assume the risk of non-payment, this scenario presents many other issues, including possible TILA and RESPA disclosure violations. The lender needs to determine what information it has in its possession. If the loan originator has enough information from the potential applicant to identify the property and is willing to order an appraisal (and take the risk of not being paid for the appraisal), it is probable that the LO has sufficient information from the applicant to have an application triggering disclosure obligations.

Additionally, although a lender may look at absorbing the cost of the appraisals that do not close as a “cost of doing business”, this scenario may subject a lender to fair lending implications. It is difficult to justify having one set of applicants who are required to pay for appraisals up front (after giving an intent to proceed) but never close the transaction for whatever reason, and another group of applicants who obtain “free” appraisals because the application fails to close. If a non-protected group is receiving the benefit of these “free” appraisals, while a protected group is not receiving this benefit, there will be a fair lending issue.

In addition to fair lending concerns, Unfair Deceptive or Abusive Acts and Practices (UDAAP) should be considered. If a loan officer tells the potential applicant (who has not received a GFE or other disclosures) that the lender will order the appraisal which the applicant can pay for at a later date, the lender may be creating an impression in the applicant’s mind that the applicant is obligated to proceed with the transaction notwithstanding that he has not received the GFE or other disclosures. The purpose of the GFE is to allow the applicant to compare offers, understand the real cost of the loan, and make informed decisions in choosing a loan. In ordering the appraisal, the LO may be creating the impression that the applicant is not permitted to shop and compare loans, and must continue with the application, irrespective of the fact that the applicant has not been given sufficient information to make an informed decision in choosing a loan. This could be viewed as a deceptive practice.

The bottom line is that the appraisal ordered by the lender is for the lender’s benefit. If the potential applicant wants an appraisal to verify value prior to bidding on a property, refinancing, etc., it is best that he directly contract for his own appraisal.

Joyce Wilkins Pollison

Director/Legal & Regulatory Compliance

Lenders Compliance Group

Changed Circumstance and Redisclosure

QUESTION
It is my understanding that unless there is a “changed circumstance”, a Good Faith Estimate (GFE) is binding on the lender. What constitutes a “changed circumstance” such that a revised GFE may be redisclosed and what is the time frame for redisclosing? 

ANSWER 

As a general rule, the GFE is binding on the lender until its expiration. The exception to this rule is if there is a “changed circumstance”.

A “changed circumstance” includes: 

• Acts of God, War, Disaster or other emergencies.
• New information obtained that was not relied upon when the initial GFE was provided.
• Identification of inaccurate information provided by the Borrower used to prepare the GFE.
• Borrower requested changes in loan terms.
• Other changes particular to the Borrower or transaction, including without limitation, boundary disputes, need for flood insurance, or environmental problems.

Additionally, a GFE must be redisclosed if the rate is locked after the initial GFE was provided. 

[12 CFR §1024.2(b)(1), §1024.7(f)]

None of the information collected by the loan originator prior to issuing the GFE may later become the basis for a “changed circumstance” upon which a loan originator may redisclose the GFE unless the loan originator can demonstrate that there was a change in the particular information or that it was inaccurate, or that the loan originator did not rely on that particular information in issuing the GFE.

The loan originator is presumed to have relied on the Borrower’s name, the Borrower’s monthly income, the property address, an estimate of the value of the property, the mortgage loan amount sought, and any information contained in any credit report obtained by the loan originator prior to providing the GFE.

Examples of situations where the reissuance of a GFE is warranted include, without limitation, the following:

• Rate lock expiration or Borrower requests a rate lock extension at a cost to Borrower.
• Loan amount changes due to Borrower request, change to payoff amount, change to obligations.
• Borrower requests an escrow waiver or decides to no longer waive escrow.
• Borrower estimated property value not supported by appraisal.
• Credit quality change due to new information received such as FICO score, DTI, undisclosed debts, judgments, income change.
• Occupancy change (i.e., property initially thought to be a primary residence becomes investment property).

Some situations must be evaluated on a case-by-case basis to determine if a changed circumstance occurred. Such situations include, without limitation:

• Borrower not proceeding quickly to closing.
• Parties added or removed from title.
• Signing documents using a power of attorney.
• Vendor for a settlement service goes out of business.
• Property type changes (i.e., single family residence is actually multi-family).
• GSE, FHA, mortgage insurance program changes.

Situations which do not qualify as a changed circumstance include, without limitation, the following:

• Lender does not accept broker issued GFE.
• Market fluctuations on a locked loan.
• Borrower’s name.
• Information in a credit report generated before the issuance of the GFE.
• Any change which is known or should have been known by the loan originator at the time the initial GFE was issued.

If a changed circumstance exists, a revised GFE must be provided to the Borrower within 3 business days of receipt of information sufficient to establish a changed circumstance.

It is important to bear in mind that information related to a changed circumstance may come from a party other than a borrower (i.e., an appraisal with a value other than expected which increases or decreases the loan amount). 

The revised GFE can only reflect the changes which increased as a direct result of the changed circumstance. The changed circumstance should be documented and all documentation and information must be maintained for at least 3 years.

The above discussion reflects regulations in effect as of this date.  The reader should bear in mind that the Consumer Financial Protection Bureau has proposed a rule integrating mortgage disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth-in-Lending Act (Regulation Z) which will alter the definition of “changed circumstance”. The proposed rule can be found at https://federalregister.gov/a/2012-17663.

Joyce Pollison
Director/Legal and Regulatory Compliance
Lenders Compliance Group