offered by
Consent Order

Consent Order Susan Moore Kelly

Date: 01/21/2014
Organization: Division of Banks
Docket Number: 2011-086

Table of Contents


Suffolk, SS.

Docket No. 2011-086


In the Matter of


Mortgage Loan Originator License No: MLO12675

WHEREAS, SUSAN MOORE KELLY (“Susan Kelly”), a licensed mortgage loan originator under Massachusetts General Laws chapter 255F, section 2 and 209 CMR 41.00 et seq., has been advised of her right to Notice and Hearing pursuant to Massachusetts General Laws chapter 30A, section 10 and chapter 255F, section 11, and having waived those rights, entered into a STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER (“Consent Agreement”) with representatives of the Division of Banks (“Division”) dated January 21, 2014, whereby, solely for the purpose of settling this matter, Susan Kelly agrees to the issuance of this CONSENT ORDER (“Consent Order”) by the Commissioner of Banks (“Commissioner”);

WHEREAS, the Division, through the Commissioner, has jurisdiction over the licensing and regulation of persons and entities engaged in the business of a mortgage loan originator in Massachusetts pursuant to Massachusetts General Laws chapter 255F, section 2;

WHEREAS, Susan Kelly’s employing entity of record in the National Mortgage Licensing System (“NMLS”) from June 18, 2008 to the present is William Raveis Mortgage, LLC, NMLS ID No. 2630, located in Shelton, Connecticut; 

WHEREAS, pursuant to General Laws chapter 255F, section 4(b), a mortgage loan originator may be employed by no more than one entity;

WHEREAS, on October 28, 2010, pursuant to the authority granted under Massachusetts General Laws chapter 255E, section 8, the Division commenced an examination/inspection ("examination/inspection") of the books, accounts, papers, records, and files maintained by Covenant Mortgage, LLC, Westford, Massachusetts, license no. MC2963;  

WHEREAS, the Division’s review of books and records during the examination/inspection revealed that Susan Kelly originated two (2) Massachusetts residential mortgage loan applications on behalf of Covenant Mortgage, LLC at a time during which, according to her NMLS record, she was sponsored by William Raveis Mortgage, LLC; and

WHEREAS, the parties now seek to resolve by mutual agreement, the aforementioned matters.


NOW COME the parties in the above-captioned matter, the Division and Susan Kelly, and stipulate and agree as follows:

  1. On or before the thirtieth day after the effective date of this Consent Order, Susan Kelly shall submit a payment of two thousand ($2,000.00) in satisfaction of an administrative penalty collected in consideration of Susan Kelly originating two (2) residential mortgage loan applications on behalf of an entity that was not Susan Kelly’s sponsoring employer of record.  Susan Kelly shall remit payment in full of the amount indicated above, payable to the “Commonwealth of Massachusetts”, to the Office of the Commissioner of Banks, 1000 Washington Street, 10th Floor, Boston, Massachusetts 02118. 
  2. This Consent Order shall become effective immediately upon the date of its issuance. 
  3. The provisions of this Consent Order shall remain effective and enforceable except to the extent that, and until such time as, any provisions of this Consent Order shall have been modified, terminated, suspended, or set aside by the Commissioner or upon an order of a court of competent jurisdiction.
  4. This Consent Order and the Consent Agreement are the complete documents that represent the resolution of this matter.  There are no other agreements, promises, representations, or warranties other than those set forth in this Consent Order and the Consent Agreement.


Dated at Boston, Massachusetts, this 21st day of January, 2014

David J. Cotney
Commissioner of Banks
Commonwealth of Massachusetts