EverBank Consent OrderPage 3 of 24
(c) failed to devote to its foreclosure processes adequate oversight, internal controls,policies, and procedures, compliance risk management, internal audit, third partymanagement, and training; and(d) failed sufficiently to oversee outside counsel and other third-party providershandling foreclosure-related services.
Board Oversight of Compliance with Order.
3. Within five (5) days, the Board shall designate a committee to monitor and coordinate theAssociation’s compliance with the provisions of this Order (Oversight Committee). TheOversight Committee shall be comprised of three (3) or more directors, which at least two (2)may not be employees or officers of the Association or any of its subsidiaries or affiliates.4. Within ninety (90) days, and within thirty (30) days after the end of each quarterthereafter, the Oversight Committee shall submit a written compliance progress report to theBoard (Compliance Tracking Report). The Compliance Tracking Report shall, at a minimum:(a) separately list each corrective action required by this Order;(b) identify the required or anticipated completion date for each corrective action; and(c) discuss the current status of each corrective action, including the action(s) takenor to be taken to comply with each corrective action.5. Within ten (10) days of receipt of the Compliance Tracking Report, the Board shallreview the Compliance Tracking Report and all reports required to be prepared by this Order.Following its review, the Board shall adopt a resolution: (a) certifying that each director hasreviewed the Compliance Tracking Report and all required reports; and (b) documenting anycorrective actions taken. A copy of the Compliance Tracking Report and the Board resolution