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Priority review Enforcement Amended Final

Nordstrom Leiren & Associates Inc.; Ingunn Borhaug Leiren - $30,000 Fine, License Revocations, Five-Year Prohibition

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Summary

The Washington State Department of Financial Institutions issued Final Order C-23-3632-26-FO01 against Nordstrom, Leiren & Associates Inc. and Ingunn Borhaug Leiren, revoking their mortgage broker and loan originator licenses respectively, imposing a $30,000 fine, and prohibiting both from the mortgage broker industry for five years. The enforcement action resulted from Respondents' failure to comply with a 2024 Consent Order by not removing Ingunn Borhaug Leiren as Designated Broker by June 1, 2025, leading to summary judgment in the Department's favor. The fine is due within 30 days of receipt of the order.

Why this matters

Mortgage brokers and loan originators in Washington State with prior examination findings should review their compliance with any existing consent orders or enforcement agreements — the consequence of non-compliance demonstrated here is license revocation and a $30,000 fine, not merely continued monitoring. The repeated violations cited across the 2015, 2017, 2019, and 2023 examinations suggest that escalation from consent order to final revocation is likely when remediation requirements are not met.

AI-drafted from the source document, validated against GovPing's analyst note standards . For the primary regulatory language, read the source document .
Published by WA DFI on dfi.wa.gov . Detected, standardized, and enriched by GovPing. Review our methodology and editorial standards .

About this source

GovPing monitors WA DFI Enforcement Actions for new banking & finance regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 18 changes logged to date.

What changed

The Final Order revokes Nordstrom, Leiren & Associates Inc.'s mortgage broker license and Ingunn Borhaug Leiren's loan originator license, imposes a $30,000 civil fine jointly and severally, and prohibits both respondents from participating in the mortgage broker industry for five years. This enforcement action arose from respondents' failure to comply with a prior Consent Order by not removing Leiren as Designated Broker by the June 1, 2025 deadline, triggering summary judgment proceedings.\n\nMortgage brokers and loan originators licensed in Washington State should treat this enforcement as a cautionary example regarding compliance with consent order terms. The violations underlying this action include repeated findings across multiple examinations for tolerance limit failures, rate lock agreement deficiencies, and inadequate Red Flags and AML programs. Entities with compliance deficiencies should prioritize remediation before regulatory examination cycles expose them to similar escalated enforcement.

What to do next

  1. Pay a fine of $30,000 within thirty (30) days of receipt of this order

Penalties

Civil fine of $30,000 jointly and severally imposed on Nordstrom, Leiren & Associates Inc. and Ingunn Borhaug Leiren, due within 30 days of receipt of the order.

Archived snapshot

Apr 28, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

ORDER SUMMARY Consumer Services Division Case Number C-23-3632 Final Orders resolve investigations where companies or individuals have been charged and then the Department has imposed sanctions. Once DFI serves the Final Order on the individual or company, the company or individual has 10 days to petition (formally ask) the Director of DFI to reconsider. The company or individual can appeal in superior court. Names Nordstrom, Leiren & Associates, NMLS # 114931 Ingunn Borhaug Leiren, NMLs # 114959 Order Number C-23-3632-26-FO01 Date issued 04/14/2026 What does this Final Order require? x Must pay a fine of $30,000.00 x Respondents aren't allowed to participate in the conduct of the affairs of the Mortgage Broker business industry in Washington for a period of five years. x Respondent Nordstrom, Leiren & Associates license to conduct the business of Mortgage Broker is revoked. x Respondent Ingunn Borhaug Leiren license to conduct the business of Mortgage Loan Originator is revoked. Need more information? You can contact the Consumer Services Division, Enforcement unit at (360) 902-8703 or csenforcecomplaints@dfi.wa.gov. Please remember that we cannot provide financial or legal advice to members of the public. We also cannot release confidential information.

Last updated on 4/14/26

1 2 3 , ORDER 4 , 5 6 , 7 8

  1. DIRECTOR'S CONSIDERATION 9 Procedural History. This matter has come before the Director of the Department of Financial 10 Institutions of the State of Washington ("Director"), pursuant to RCW 34.05.464. On or about March 11 15, 2024, the Director, through his designee, Consumer Services Division Director Ali Higgs, issued 12 a Statement of Charges and Notice of Intent to Enter an Order to Revoke Mortgage Broker License, 13 Deny Application to Renew Mortgage Broker License, Revoke Designated Broker Registration, 14 Revoke Loan Originator License, Prohibit from Industry, Impose Fine, Collect Investigation Fee, and 15 Recover Costs and Expenses ("Statement of Charges") against Nordstrom, Leiren & Associates Inc. 16 and Ingunn Borhaug Leiren ("Respondents"). 17 On or about October 24, 2024, the Director, through his designee, Consumer Services 18 IN THE MATTER OF DETERMINING No.: C-23-3632-26-FO01 Division Director Ali Higgs, and Respondents entered Consent Order C-23-3632-24-CO01 ("Consent Whether there has been a violation of the 19 Mortgage Broker Practices Act of Washington by: Order") pursuant to Chapter 19.146 of the Revised Code of Washington (RCW) and RCW 34.05.060 20 NORDSTROMFINALLEIREN & ASSOCIATES INC., of the Administrative Procedure Act to resolve the issues of the Statement of Charges. Ingunn NMLS #114931 21 Borhaug Leiren agreed to surrender her Designated Broker Registration, and Nordstrom, Leiren & and 22 NMLS #114959C Respondents. Leiren

Associates Inc. agreed to remove and replace Ingunn Borhaug Leiren as its Designated Broker, by June 1, 2025. The Department of Financial Institutions of the State of Washington ("Department") agreed to stay or partially stay the following stipulated sanctions: 1

x Revocation of Nordstrom, Leiren & Associates Inc.'s license to conduct business as a

2 mortgage broker; 3

x Revocation of Ingunn Borhaug Leiren's license to conduct business as a loan originator;

x Prohibition on Nordstrom, Leiren & Associates Inc. and Ingunn Borhaug Leiren from

5 participating, in any manner, in the conduct of the affairs of any mortgage broker licensed 6 by the Department or subject to licensure or regulation by the Department for five (5) 7 years; and 8

x $40,000 monetary fine, with $10,000 to be paid upon entry of the Consent Order, leaving

9 a $30,000 fine stayed. 10 On or about July 22, 2025, the Department issued a Notice of Noncompliance with Consent 11 Order and Opportunity for Hearing to Respondents as required under the terms of the Consent Order. 12 On or about September 3, 2025, the Department received Respondents' Applications for an 13 Adjudicative Hearing. On or about September 9, 2025, the Department made a request to the Office 14 of Administrative Hearings ("OAH") to assign an Administrative Law Judge ("ALJ") to schedule and 15 conduct a hearing on the Notice of Noncompliance. 16 On September 26, 2025, OAH issued a Notice of Prehearing Conference scheduling a 17 prehearing conference and assigning ALJ TJ Martin to preside over the prehearing conference and 18 hearing proceedings. 19 On October 6, 2025, Representatives for the Department and Respondents attended a 20 telephonic prehearing conference. 21 22

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On October 14, 2025, ALJ Martin issued a Prehearing Conference Order, which included a case schedule. On December 1, 2025, the Department timely filed a Motion for Summary Judgement. On 1 January 13, 2026, ALJ Martin issued and served on the parties an Initial Order Granting 2 Department's Motion for Summary Judgment ("Initial Order"). This Initial Order decided and 3 ordered: 4

x No genuine dispute of material fact exists that Respondents failed to remove and

5 replace Ingunn Borhaug Leiren as the Designated Broker of Nordstrom, Leiren & 6 Associates Inc. before June 1, 2025. 7

x No genuine dispute of material fact exists that Respondents failed to surrender Ingunn

8 Borhaug Leiren as the Designated Broker Registration to the Department before June 9 1, 2025. 10

x Since no genuine dispute of material fact exists, as a matter of law, the Department's

11 Motion for Summary Judgment is granted. 12

x Penalties, including prohibitions from the industry, license revocation, a $30,000 fine,

13 and recovery of costs, are appropriate. 14

x The Department's Notice of Noncompliance with Consent Order and Opportunity for

15 Hearing is affirmed. 16

x Evidentiary hearing previously scheduled is stricken.

17 Pursuant to RCW 34.05.464 and WAC 10-08-211, Respondents had twenty (20) days from 18 the date of service of the Initial Order to file a Petition for Review of the Initial Order. Respondents 19 did not file a Petition for Review during the statutory period. 20

  1. Record Presented. The record presented to the Director for his review and for entry of 21 a final order included the following: 22

C Leiren

  1. Statement of Charges.
  2. Request to OAH for Assignment of Administrative Law Judge.
  3. The Department's Notice of Appearance dated September 18, 2025.

  4. Notice of Prehearing Conference dated September 26, 2025, with documentation
    of service. 2

  5. Audio File from the Prehearing Conference, dated October 6, 2025. 3

  6. Prehearing Conference Order and Notice of Video Conference Hearing dated 4

October 14, 2025, with documentation of service. 5

  1. Department's Motion for Summary Judgment.

  2. Declaration of Sandra Mendez in Support of Motion for Summary Judgment, with 7exhibits.

  3. Initial Order Granting the Department's Motion for Summary Judgement dated

January 13, 2026, and documentation of service. 9

  1. Appellant's Letter regarding case, received by OAH dated January 23, 2026. 10
  2. Factual Findings and Grounds for Order. Pursuant to RCW 34.05.461, the Director 11
    hereby adopts the Initial Order Granting the Department's Motion for Summary Judgement, which is 12 attached hereto. 13

  3. FINAL ORDER 14
    Based upon the foregoing, and the Director having considered the record and being otherwise 15 fully advised, NOW, THEREFORE: 16

  4. IT IS HEREBY ORDERED, That: 17

  5. Respondent Nordstrom Leiren & Associates Inc.'s license to conduct the business 18of mortgage broker is revoked.

  6. Respondent Ingunn Borhaug Leiren's designated broker registration is revoked.

  7. Respondent Ingunn Borhaug Leiren's license to conduct business of a loan
    originator is revoked. 21 22

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  1. Respondents Nordstrom, Leiren & Associates Inc. and Ingunn Borhaug Leiren
    shall jointly and severally pay to the Washington State Department of Financial Institutions, within thirty (30) days of receipt of this order, a fine of thirty thousand dollars ($30,000).

  2. Respondents Nordstrom, Leiren & Associates Inc. and Ingunn Borhaug Leiren are 1
    prohibited from participation in the conduct of the affairs of any mortgage broker subject to licensure by the Director, in any manner, for a period of five (5) years. 2

  3. Reconsideration. Pursuant to RCW 34.05.470, Respondents have the right to file a 3
    Petition for Reconsideration stating the specific grounds upon which relief is requested. The Petition 4 must be filed in the Office of the Director of the Department of Financial Institutions by courier at 5 150 Israel Road SW, Tumwater, Washington 98501, or by U.S. Mail at P.O. Box 41200, Olympia, 6 Washington 98504-1200, within ten (10) days of service of the Final Order upon Respondents. The 7 Petition for Reconsideration shall not stay the effectiveness of this order nor is a Petition for 8 Reconsideration a prerequisite for seeking judicial review in this matter. 9 A timely Petition for Reconsideration is deemed denied if, within twenty (20) days from the 10 date the petition is filed, the agency does not (a) dispose of the petition or (b) serve the parties with a 11 written notice specifying the date by which it will act on a petition. 12

  4. Stay of Order. The Director has determined not to consider a Petition to Stay the 13
    effectiveness of this order. Any such requests should be made in connection with a Petition for 14 Judicial Review made under chapter 34.05 RCW and RCW 34.05.550. 15

  5. Judicial Review. Respondents have the right to petition the superior court for judicial 16
    review of this agency action under the provisions of chapter 34.05 RCW. For the requirements for 17 filing a Petition for Judicial Review, see RCW 34.05.510 and sections following. 18

  6. Non-compliance with Order. If you do not comply with the terms of this order, 19
    including payment of any amounts owed within thirty (30) days of receipt of this order, the 20 Department may seek its enforcement by the Office of the Attorney General to include the collection 21 22

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of the fines imposed herein. The Department also may assign the amounts owed to a collection agency for collection.

  1. Service. For purposes of filing a Petition for Reconsideration or a Petition for Judicial 1 Review, service is effective upon deposit of this order in the U.S. mail, declaration of service 2 attached hereto. 3 DATED this 14th day of April, 2026. 4 5 6 7 _ ______________________ CHARLES E. CLARK 8 Director 9 10 11 12 13 14 15 16 17 18 19 20 21 22

Olympia, WA 98504- C ___________ Leiren CHARLES E CLARK

ORDER SUMMARY Consumer Services Division Case Number C-23-3632 Consent Orders resolve investigations. In these, companies and individuals work with us to agree to terms that resolve the alleged issues in the investigation. Names Nordstrom, Leiren & Associates, Inc., NMLS #114931 Ingunn Borhaug Leiren, NMLS #114959 Order Number C-23-3632-24-CO01 Date issued October 24, 2024 What does this Consent Order require? Must pay a fine of $10,000. Must pay a fine of $30,000. This fine is stayed (doesn't have to be paid) until October 24, 2029, as long as [Respondents] comply with the order. The fine goes away on that date if Respondents have complied. Must pay an investigation fee of $590.40. (Investigation fees cover the cost of DFI staff time working on the investigation.) Respondent Nordstrom's mortgage broker license and Respondent Leiren's loan originator license revocations are stayed until October 24, 2029. Respondent Leiren shall be removed as Designated Broker by June 1, 2025. Respondent Leiren shall surrender Designated Broker registration by June 1, 2025. Respondents' prohibition from the industry is stayed until October 24, 2029. Respondents must undergo a compliance examination by October 24, 2029. Respondents must maintain compliance with all applicable laws and regulations, and maintain an Anti-Money Laundering and Red Flags program in compliance in with all applicable laws and regulations. Need more information? You can contact the Consumer Services Division, Enforcement unit at (360) 902-8703 or csenforcecomplaints@dfi.wa.gov. Please remember that we cannot provide financial or legal advice to members of the public. We also cannot release confidential information.

Last updated 11/4/24

24th

October

DIVISION OF CONSUMER SERVICES 1 Act of Washington STATEMENT OF CHARGES and NOTICE OF INTENT TO ENTER AN 2 ORDER TO REVOKE MORTGAGE ASSOCIATES INC, BROKER LICENSE, DENY APPLICATION 3 , TO RENEW MORTGAGE BROKER LICENSE, REVOKE DESIGNATED 4 BORHAUG LEIREN, BROKER REGISTRATION, REVOKE and Mortgage Loan LOAN ORIGINATOR LICENSE, PROHIBIT 5 NMLS # 114959, FROM INDUSTRY, IMPOSE FINE, COLLECT INVESTIGATION FEE, and 6 7 INTRODUCTION 8 Pursuant to RCW 19.146.220 and RCW 19.146.223, the Director of the Department of 9 Financial Institutions of the State of Washington (Director) is responsible for the administration of 10 chapter 19.146 RCW, the Mortgage Broker Practices Act (Act). After having conducted an 11 investigation pursuant to RCW 19.146.235, and based upon the facts available as of the date of this 12 Statement of Charges, the Director, through his designee, Division of Consumer Services Acting 13 Director Ali Higgs, institutes this proceeding and finds as follows: 14

  1. FACTUAL ALLEGATIONS15
    1.1 Respondents. 16

  2. Nordstrom, Leiren & Associates Inc (Respondent Nordstrom) was licensed by the
    17 Department of Financial Institutions of the State of Washington (Department) to conduct business as IN THE MATTER OF DETERMINING No. C-23-3632-24-SC01 18 a mortgage broker on or about May 24, 1994, and continues to be licensed to date. On or about Whether there has been a violation of the Mortgage Broker Practices19 December 6, 2023, Respondent Nordstrom submitted a request to renew its mortgage broker license by: 20 with the Department. As of the date of this Statement of Changes, that request is currently pending. NORDSTROM, LEIREN & NMLS # 11493121 and INGUNN 22 Owner, Designated Broker, Originator, RECOVER COSTS AND EXPENSES Respondents.

  3. Ingunn Borhaug Leiren (Respondent Leiren) is the Owner, Designated Broker, and
    Mortgage Loan Originator of Respondent Nordstrom. Respondent Leiren was named Designated Broker of Respondent Nordstrom on or about January 5, 2010, and continues to be Designated Broker 1 to date. Respondent Leiren was licensed by the Department to conduct business as a loan originator 2 on or about January 5, 2010, and continues to be licensed to date. 3 1.2 Prior Examinations. The Department conducted compliance examinations of Respondent 4 Nordstrom in 2015, 2017, and 2019. The Report of Examination (ROE) from February 28, 2015, 5 identified 15 violations of the law. The ROE from April 30, 2017 identified 23 violations, 10 of which 6 were repeat findings. The ROE from May 31, 2019 identified 10 violations, 8 of which were repeat 7 findings. 8 1.3 Prior Enforcement Action. As a result of the 2017 examination, on or about March 30, 2018, 9 the Department issued a Statement of Charges and Notice of Intent to Enter an Order to Cease and 10 Desist, Revoke Licenses, Prohibit from Industry, Impose Fine, Collect Investigation Fee, and Recover 11 Cost and Expenses (2018 Statement of Charges). On June 22, 2018, the Department and the 1 12 Respondents entered into a Consent Order to resolve the 2018 Statement of Charges. Respondents 2 13 agreed to cease and desist from violating the Act, agreed to hire an outside Compliance Officer to 14 oversee their business practices, and paid the fine and investigation fees. Further, the licenses 15 revocations and the prohibition from industry were stayed for two (2) years. 16 1.4 2023 Examination. From August 7, 2023, through August 10, 2023, the Department 17 conducted a compliance follow-up examination of Respondent Nordstrom business practices for the 18 period of April 1, 2021, through April 30, 2023. The Department determined that Respondent 19 20

21 Statement of Charges No. C-17-2265-18-SC01. 1 Consent Order No. C-17-2265-18-CO01. 222

Nordstrom violated the Act as detailed below that included four findings of repeat violations noted on prior examinations, and two cited for the fourth consecutive examination. 1.5 Engaged in Misleading and Deceptive Practices. Respondent Nordstrom provided pre- 1 approval letters to at least five (5) Washington borrowers without first obtaining approval from a 2 lender or an automated underwriting system (AUS). In at least two (2) instances, Respondent 3 Nordstrom issued pre-approval letters to Washington borrowers that stated the company had made the 4 pre-approval decision after evaluating the borrower's credit, income and assets, when this information 5 was not true as the company did not have the credit report or income and asset information until after 6 the letter was issued. 7 1.6 Did not Adhere to Tolerance Limits. This is a repeat finding cited by the Department for 8 three consecutive examinations from 2017, 2019, and 2023. On or about November 4, 2021, 9 Respondent Nordstrom issued an initial Loan Estimate (LE) to a Washington borrower that indicated 10 that the borrower was permitted to shop for title and escrow services. The LE disclosed a lender's title 11 insurance fee, settlement fee, and recording fees that at settlement were charged with an increase 12 totaling more than the 10% tolerance allowed by law. On or about April 8, 2022, Respondent 13 Nordstrom issued an LE to another Washington borrower that disclosed appraisal fees that at 14 settlement were charged in amount that was higher than initially estimated which is more than the 0% 15 tolerance allowed by law. 16 1.7 Did not Provide a Rate Lock Agreement within Three Business Days. Respondent 17 Nordstrom did not provide at least 10 Washington borrowers with a rate lock agreement within three 18 business days after locking or changing the borrower's interest rate or extending the rate lock period. 19 This is a repeat finding from all three (3) previous exams of 2015, 2017, and 2019. 20 1.8 Did not Develop and Implement a Compliant Red Flags Program. Respondent Nordstrom 21 provided to the Department a five-page document titled "Red Flags Policy and Identity Theft 22

Prevention Program" that was undated and unsigned and appears to be a generic model not specific to the mortgage industry. Additionally, it did not designate an administrator to monitor compliance and update as needed and did not disclose the frequency of staff training dedicated to preventing identity 1 theft. 2 1.9 Did not Develop and Implement an Anti-Money Laundering Program. Respondent 3 Nordstrom provided to the Department an Anti-Money Laundering Program (AML) for the exam 4 period that Respondent Nordstrom approved after the examination was completed. The program did 5 not clearly specify frequency of independent testing of the program, did not include a manager 6 approval and implementation date, and appears to be a model not specific to a mortgage broker. This 7 is a repeat finding from all three (3) previous exams of 2015, 2017, and 2019. 8 1.10 Did not Maintain Records. Respondent Nordstrom did not maintain complete loan records 9 for at least seven (7) borrowers. For the seven (7) incomplete loan files, Respondent Nordstrom did 10 not provide the Department with 22 documents required to be maintained as part of the loan files. 11 1.11 Did not Provide a Privacy Policy. Respondent Nordstrom did not provide a privacy policy 12 disclosure to at least 21 borrowers when a customer relationship was established between Respondent 13 Nordstrom and the borrowers. 14 1.12 Conducted Business Using Only the Registered Trade Name. Respondent Nordstrom 15 conducted business using only the registered trade name Leiren & Associates without also using the 16 company's main license name or license number on pre-approval letters and disclosures issued to at 17 least 17 borrowers. 18 1.13 On-Going Investigation. The Department's investigation into the alleged violations of the 19 Act by Respondents continues to date. 20 // 21 // 22

  1. GROUNDS FOR ENTRY OF ORDER 2.1 Responsibility for Conduct of Employees. Pursuant to RCW 19.146.245, a licensed mortgage broker is liable for any conduct violating the Act by the designated broker, a loan originator, 1 or other licensed mortgage broker while employed or engaged by the licensed mortgage broker. 2 2.2 Responsibility of Designated Broker. Pursuant to RCW 19.146.200(3), every licensed 3 mortgage broker must at all times have a designated broker responsible for all activities of the 4 mortgage broker in conducting the business of a mortgage broker. A designated broker, principal, or 5 owner who has supervisory authority over a mortgage broker is responsible for a licensee's, 6 employee's, or independent contractor's violations of the Act if: the designated broker, principal, or 7 owner directs or instructs the conduct or, with knowledge of the specific conduct, approves or allows 8 the conduct; or the designated broker, principal, or owner who has supervisory authority over the 9 licensed mortgage broker knows or by the exercise of reasonable care and inquiry should have known 10 of the conduct, at a time when its consequences can be avoided or mitigated and fails to take reasonable 11 remedial action. 12 2.3 Prohibited Acts. Based on the Factual Allegations set forth in Sections 1.5, 1.6, and 1.7, 1.8, 13 1.9, and 1.11 above, Respondents are in apparent violation of RCW 19.146.0201(2), (7) and (11), and 14 WAC 208-660-500(3)(a),(b), and (r) by directly or indirectly engaging in any unfair or deceptive 15 practice toward any person and failing to comply with federal statutes and regulations. 16 2.4 Fiduciary Duties. Based on the Factual Allegations set forth in Section 1.5 above Respondents 17 are in apparent violation of RCW 19.146.095(1)(d) by failing to use reasonable care in performing its 18 duties. 19 2.5 Requirement to Adhere to Tolerance Limits. Based on the Factual Allegations set forth in 20 Section 1.6 above, Respondents are in apparent violation of RCW 19.146.0201(11), and RCW 21 22

19.146.030(4) by failing to adhere to tolerance limits as required by Regulation Z, 12 C.F.R. § 1026.19(e). 2.6 Requirement to Provide a Rate Lock Agreement within Three Business Days. Based on 1 the Factual Allegations set forth in Section 1.7 Respondents are in apparent violation of RCW 2 19.146.030(1) and (2), and WAC 208-660-430(1), (3)(c), and (6) by failing to ensure borrowers were 3 provided with a rate lock agreement within three (3) business days as required. 4 2.7 Requirement to Develop and Implement a Compliant Red Flags Program. Based on the 5 Factual Allegations set forth in Section 1.8 above, Respondents are in apparent violation of RCW 6 19.146.0201(11) by failing to develop and implement a compliant red flags program as required by 7 the Federal Trade Commission, Fair Credit Reporting Act, 16 CFR, Part 681.1(d), (e), and (f). 8 2.8 Requirement to Develop and Implement a Compliant Anti-Money Laundering Program. 9 Based on the Factual Allegations set forth in Section 1.9 above, Respondents are in apparent violation 10 of RCW 19.146.0201(11) by failing to develop and implement a compliant anti-money laundering 11 program as required by the FinCEN, Department of the Treasury, 31 C.F.R. §1029.210. 12 2.9 Recordkeeping Requirements. Based on the Factual Allegations set forth in Section 1.10 13 above, Respondents are in apparent violation of RCW 19.146.060(2), and WAC 208-660-450(3) and 14 (4)(a) by failing to maintain complete loan records and failing to provide them for the Department's 15 examination. 16 2.10 Requirement to Provide Privacy Policy Disclosure. Based on the Factual Allegations set 17 forth in Section 1.11 above, Respondents are in apparent violation of RCW 19.146.0201(11) and WAC 18 208-660-470(1)(a) by failing to provide Initial Privacy Notice to consumers as required under the 19 Gramm-Leach-Bliley Act and Regulation P, 12 C. F.R. § 1016.4(a), (c)(1) and (2). 20 2.11 Requirement when Using a Registered Trade Name. Based on the Factual Allegations set 21 forth in Section 1.12 above, Respondents are in apparent violation of RCW 19.146.0201(2) and WAC 22

208-660-180(9) by conducting business with its trade name without using it together with the company's main licensed name or the license number.

  1. AUTHORITY TO IMPOSE SANCTIONS 1 3.1 Authority to Revoke License and Deny Renewal Application. Pursuant to RCW
    2 19.146.220(2), the Director may revoke licenses and decline to renew licenses for any violation of the 3 Act. 4 3.2 Authority to Prohibit from Industry. Pursuant to RCW 19.146.220(4), the Director may 5 issue orders prohibiting from participation in the conduct of the affairs of a licensed mortgage broker, 6 any officer, principal, employee, or loan originator of any licensed mortgage broker or any person 7 subject to licensing under the Act for any violation of the Act. 8 3.3 Authority to Impose Fine. Pursuant to RCW 19.146.220(2) and WAC 208-660-530(6), the 9 Director may impose a fine of up to $100 per day against a licensee for each violation of the Act. 10 3.4 Authority to Collect Investigation Fee. Pursuant to RCW 19.146.228(2), WAC 208-660- 11 520(9) & (11), and WAC 208-660-550(4)(a), the Department will charge forty-eight dollars per hour 12 for an examiner's time devoted to an investigation. 13 3.5 Authority to Recover Costs and Expenses. Pursuant to RCW 19.146.221(2), the Director 14 may recover the state's costs and expenses for prosecuting violations of the Act. 15

  2. NOTICE OF INTENT TO ENTER ORDER 16 Respondents' violations of the provisions of chapter 19.146 RCW and chapter 208-660 WAC,
    17 as set forth in the above Factual Allegations, Grounds for Entry of Order, and Authority to Impose 18 Sanctions, constitute a basis for the entry of an Order under RCW 19.146.220, RCW 19.146.221, and 19 RCW 19.146.223. Therefore, it is the Director's intent to ORDER that: 20 4.1 Respondent Nordstrom, Leiren & Associate Inc's license to conduct the business of a mortgage broker be revoked. 21 22

4.2 Respondent Ingum Borgaug Leiren's designated broker registration be revoked. 4.3 Respondent Ingum Borhaug Leiren's license to conduct the business of a loan originator be revoked. 4.4 Respondent Nordstrom, Leiren & Associate Inc be prohibited from participation in 1 the conduct of the affairs of any mortgage broker subject to licensure by the Director, in any manner, for a period of 5 years. 2 4.5 Respondent Nordstrom, Leiren & Associate Inc be prohibited from participation in 3 the conduct of the affairs of any mortgage broker subject to licensure by the Director, in any manner, for a period of 5 years. 4 4.6 Respondents Nordstrom, Leiren & Associate Inc and Respondent Ingum Borhaug 5 Leiren jointly and severally pay a fine. As of the date of this Statement of Charges, the fine totals $54,100. 6 4.7 Respondents Nordstrom, Leiren & Associate Inc and Respondent Ingum Borhaug 7 Leire jointly and severally pay an investigation fee. As of the date of this Statement of Charges, the investigation fee totals $590.40. 8 4.8 Respondents Nordstrom, Leiren & Associate Inc and Respondent Ingum Borhaug 9 Leire maintain records in compliance with the Act and provide the Department with the location of the books, records and other information relating to Respondents 10 mortgage broker business, and the name, address, and telephone number of the individual responsible for maintenance of such records in compliance with the Act. 11 4.9 Respondents Nordstrom, Leiren & Associate Inc and Respondent Ingum Borhaug 12 Leire jointly and severally pay the Department's costs and expenses for prosecuting violations of the Act in an amount to be determined at hearing or by declaration with 13 supporting documentation in event of default by Respondent. 14 // 15 // 16 // 17 // 18 // 19 // 20 // 21 22

  1. AUTHORITY AND PROCEDURE This Statement of Charges is entered pursuant to the provisions of RCW 19.146.220, RCW 19.146.221, RCW 19.146.223, and RCW 19.146.230, and is subject to the provisions of chapter 34.05 1 RCW (the Administrative Procedure Act). Respondents may make a written request for a hearing as 2 set forth in the NOTICE OF OPPORTUNITY TO DEFEND AND OPPORTUNITY FOR HEARING 3 accompanying this Statement of Charges. 4 5 Dated this 15th day of March 2024. 6 7 ______________ Ali Higgs, Acting Director 8 Department of Financial Institutions 9 10 Presented by: 11 __ ___ 12 SANDRA MÉNDEZ Financial Legal Examiner 13 Reviewed by: 14 _ _______ 15 KENDALL H. FREED Financial Legal Examiner Supervisor 16 Approved by: 17 18 _ _____ JAMES R. BRUSSELBACK 19 Acting Enforcement Chief 20 21 22

CFR references

12 CFR 1026.19(e) 12 CFR 1016.4 16 CFR 681.1 31 CFR 1029.210

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Last updated

Classification

Agency
WA DFI
Filed
April 14th, 2026
Instrument
Enforcement
Branch
Executive
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
C-23-3632-26-FO01

Who this affects

Applies to
Brokers Mortgage companies
Industry sector
5221 Commercial Banking
Activity scope
Mortgage broker licensing Loan originator licensing Mortgage lending compliance
Geographic scope
Washington US-WA

Taxonomy

Primary area
Consumer Finance
Operational domain
Compliance
Compliance frameworks
BSA/AML Dodd-Frank
Topics
Anti-Money Laundering Consumer Protection

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