TECHNICAL VIOLATION OF TILA IN NOTICE OF RIGHT TO CANCEL DOES NOT EXTEND RESCISSION PERIOD FOR BORROWER (AT LEAST ON THE EAST COAST)
FACTS
In April 2006, Joseph Melfi refinanced his home mortgage with WMC Mortgage Corp. At the closing, Melfi received from WMC a notice of his right to rescind the transaction. The notice is required for such a transaction by the Truth in Lending Act. Assuming that the notice complies with TILA, a borrower is given three business days to rescind the transaction; otherwise, the period is much longer. The question in this case is whether the notice given Melfi adequately complied.
Under TILA, the requirements for the notice are established by the Federal Reserve Board in its Regulation Z. Failure to provide proper notice extends to three years the borrower's deadline to rescind.
About 20 months after the closing, Melfi attempted to rescind the transaction. The incentives for a borrower to do so may be substantial where a new loan is available, especially if rates have fallen or substantial interest has been paid during the period of the original loan. "When a consumer rescinds a transaction . . . the consumer shall not be liable for any amount, including any finance charge," and "the creditor shall return any money or property that has been given to anyone in connection with the transaction."
Melfi argued that the notice of his right to cancel was deficient because it left blank the spaces for the date of the transaction (although the date was stamped on the top right corner of the notice) and the actual deadline to rescind. WMC and co-defendants Deutsche Bank and Wells Fargo (the loan's trustee and servicer, respectively) refused to allow the rescission, and Melfi then brought this action in the federal district court in Rhode Island. The District Court ruled that even if the omissions in the notice were violations, they were at most technical violations that did not give rise to an extended rescission period because the notice was clear and conspicuous despite the omissions, and it dismissed Melfi's complaint.
The 1st District of the U. S. Court of Appeals said affirmed. TILA provides that "[t]he creditor shall clearly and conspicuously disclose, in accordance with regulations of the Board, to any obligor in a transaction subject to this section the rights of the obligor under this section." 15 U.S.C. § 1635(a). Regulation Z says what the notice of the right to cancel must clearly and conspicuously disclose; pertinently, the regulation requires that the notice include "[t]he date the rescission period expires." The Board has created a model form; a creditor must provide either the model form or a "substantially similar notice." The use of the model form insulates the creditor from most insufficient disclosure claims. 15 U.S.C. § 1604(b). WMC gave Melfi the model form, but the spaces left for the date of the transaction and the date of the rescission deadline were not filled in. The form Melfi received had the date of the transaction stamped at its top (but it was not so designated) and then read in part:
You are entering into a transaction that will result in a mortgage/lien/security interest on your home. You have a legal right under federal law to cancel this transaction, without cost, within THREE BUSINESS DAYS from whichever of the following events occurs LAST:
(1) The date of the transaction, which is ____________; or
(2) The date you receive your Truth in Lending disclosures; or
(3) The date you received this notice of your right to cancel.
HOW TO CANCEL
If you decide to cancel this transaction, you may do so by notifying us in writing. . . .
You may use any written statement that is signed and dated by you and states your intention to cancel and/or you may use this notice by dating and signing below. Keep one copy of this notice because it contains important information about your rights.
If you cancel by mail or telegram, you must send the notice no later than MIDNIGHT of _____________ (or MIDNIGHT of the THIRD BUSINESS DAY following the latest of the three events listed above). If you send or deliver your written notice to cancel some other way, it must be delivered to the above address no later than that time.
Melfi argues Regulation Z requires in substance the deadline for rescission be provided; one of the three measuring dates -- the date of the transaction -- was left blank (the other two are described but have no blanks); and therefore the notice was deficient and Melfi has three years to rescind. A number of district court cases, along with two circuit court opinions, support Melfi's position, E.g., Semar v. Platte Valley Fed. Sav. & Loan Ass'n, 791 F.2d699, 702-03 (9th Cir. 1986); Williamson v. Lafferty, 698 F.2d 767,768-69 (5th Cir. 1983); Johnson v. Chase Manhattan Bank, USA N.A.,No. 07-526, 2007 WL 2033833, at *3 (E.D. Pa. July 11, 2007);Reynolds v. D & N Bank, 792 F. Supp. 1035, 1038 (E.D. Mich. 1992).
District court decisions in the First Circuit Court of Appeals conclude that failing to fill in a blank did not automatically trigger a right to rescind. Bonney v. Wash. Mut. Bank, 596 F. Supp. 2d 173 (D. Mass.2009); Megitt v. Indymac Bank, F.S.B., 547 F. Supp. 2d 56 (D. Mass.2008); Carye v. Long Beach Mortgage Co., 470 F. Supp. 2d 3 (D.Mass. 2007).
Technical deficiencies do not matter if the borrower receives a notice that effectively gives him notice as to the final date for rescission and has the three full days to act. The test is whether any reasonable person, in reading the form provided in this case, would so understand it. Here, the omitted dates made no difference. The date that Melfi closed on the loan can hardly have been unknown to him and was in fact hand stamped or typed on the form given to him. From that date, it is easy enough to count three days; completing the blank avoids only the risk created by the fact that Saturday counts as a business day under and the borrower might think otherwise. Lafferty, 698 F.2d at 769 n.3 ("[T]he precise purpose of requiring the creditor to fill in the date [of the rescission deadline] is to prevent the customer from having to calculate three business days").
Nor does completing the blank necessarily tell the borrower how long he has to rescind. Where after the closing the borrower is mailed either the notice or certain other required information, the three days runs not from the transaction date but from the last date when the borrower receives the notice and other required documents. Melfi himself says he was given the form on the date of the closing and does not claim that there was any pertinent delay in giving him the other required disclosures. So the blanks in no way misled Melfi in this case.
So the argument for allowing Melfi to extend his deadline from three days to three years depends on this premise: that any flaw or deviation should be penalized automatically in order to deter such errors in the future.
There is no evidence in TILA or any Board regulation that either Congress or the Board intended to render the form a nullity because of an uncompleted blank in the form or similar flaw where, as here, it could not possibly have caused Melfi to think that he had months in order to rescind. The central purpose of the disclosure -- the short notice period for rescission at will -- was plain despite the blanks. Melfi's argument assumes, rather than establishes, that a penalty was intended.
Some cases finding a blank notice form to be grounds for rescission even though harmless were decided under an earlier version of TILA. In 1995, Congress added a new subsection to TILA, titled "Limitation on Rescission Liability." It provided that a borrower could not rescind "solely from the form of written notice used by the creditor . . . if the creditor provided the [borrower] the appropriate form of written notice published and adopted by the Board." 15 U.S.C. § 1635(h).
The TILA amendments were aimed in general to guard against widespread rescissions for minor violations. To this extent, Congress has now leaned against a penalty approach and, perhaps, weakened the present force of the older case law favoring extension of the rescission deadline. Where, as here, the Board's form was used and a reasonable borrower cannot have been misled, allowing a windfall and imposing a penalty serves no purpose. (Melfi vs. WMC Mortgage Corp. U.S.C.A. 1st Cir. 6-11-09)
MORAL
This is one for the lenders, but only in the First Circuit which is on the East Coast. The West Coast still holds the other way. So be careful and fill the entire blanks as required and avoid the law suit in the first instance.
LOS ANGELES MAN ARRESTED FOR FILING FALSE BANKRUPTCIES TO PREVENT FORECLOSURES
FACTS
Gilfert Welton Jackson was arrested on June 10, 2009 for defrauding homeowners by falsely promising them he could prevent foreclosures and evictions from their property. Jackson made his initial court appearance on June 11 in United States District Court in Los Angeles, where he was ordered detained until he posts a $25,000 bond.
Jackson was indicted on June 4 and charged with six counts of making false representations and filing documents in bankruptcy proceedings in furtherance of a scheme to defraud. According to the indictment, which was unsealed after his arrest, Jackson's scheme was designed to bilk distressed homeowners, as well as banks and other creditors by fraudulently obstructing lawful foreclosure and eviction actions.
The indictment alleges that Jackson falsely passed himself off as an attorney. Jackson allegedly told property owners and their tenants that he could prevent foreclosure and unlawful detainer and eviction actions in exchange for payments to purported non-profit organizations, including Silver Dollar Classic Foundation Inc., and Herd Community Development Corp. Jackson and others filed bankruptcy petitions to obtain an automatic stay, which prevents any action against the bankruptcy debtor and his property. Jackson created fraudulent notices of automatic stay that he gave to banks, their agents and others, including the Los Angeles County Sheriff's Department, who were attempting to foreclose on properties and litigate unlawful detainer actions. In each such notice of automatic stay, Jackson fraudulently represented that the identified property was owned by a debtor in bankruptcy and was, therefore, subject to the automatic stay.
The indictment alleges that Jackson's scheme victimized homeowners, who paid Jackson for his worthless services. According to the indictment, during the period of delay that Jackson caused, Jackson collected rent from third parties living in the properties based on the false representation that he was the rightful landlord of the properties.
Jackson was previously convicted of bankruptcy fraud in 1998 and sentenced to 63 months in federal prison. In 2006, the Bankruptcy Court for the Central District of California issued an order that forbade Jackson from filing any bankruptcy petitions or any other documents, without first obtaining Court approval to do so.
If he is convicted of the six counts of bankruptcy fraud alleged in the indictment, Jackson would face a maximum statutory penalty of 30 years in federal prison. (usattyla61109)
MORAL
Remember, he is innocent until proven guilty. But lord help him if proven guilty having been previously convicted of the same crime.
CALIFORNIA BANKRUPTCY FILINGS SOAR DUE TO RECESSION
FACTS
In the 12 months ending March 2009, bankruptcy filings in California were up over 80%. Most of these are in the Central District of California covering Los Angeles County, Orange County, San Luis Obispo County, San Bernardino County, Riverside County and two other counties. The total filed in the 12-month period amounted to 75,000 or a little over 6,000 per month amounting to a little over 200 per day each and every day of the month in the seven-county region covering the Los Angeles area. In the state over 130,000 were filed in the same seven-month period or about 300 each and every day. That is a lot of bankruptcies primarily due to foreclosures. This holds true in other large foreclosure states such as Nevada, Arizona and Florida. (ladj4409p2)
MORAL
Exotic mortgages equal more bankruptcies? If you know someone contemplating bankruptcy, have him or her call me. The consultation over the phone is free.
IF YOU HAVE A BORROWER THAT NEEDS TO CONFER ON BANKRUPTCY HAVE HIM CALL ME. TELL HIM THE TELEPHONE CONFERENCE IS FREE. WE HAVE A BANKRUPTCY ATTORNEY ON STAFF THAT TAKES CARE OF IT LEGITIMATELY.
FLORIDA MAN DRAWS 33 MONTHS IN FEDERAL PRISON FOR FORECLOSURE SCAM
FACTS
Sergei Tews pleaded guilty to a fraud scheme where he filed and foreclosed on false mortgages in Florida. He was sentenced to 33 months in prison. He also was sentenced to three years of supervised release following the prison term and ordered to pay $636,000 in restitution.
Tews persuaded homeowners to transfer their properties to him in exchange for his promise to assume their mortgage payments. He had the homeowners execute warranty deeds, which gave the appearance that the properties were sold to a third party instead of being transferred to Tews. He then falsified the amount paid for each property, paid the filing taxes based on the false amount and filed fraudulent mortgages on each property. At the foreclosure sales, third-party purchasers were deceived into believing that there were no pre-existing mortgages on the properties and bid on and bought the properties at auction. After the third-party purchasers paid for the properties, the court issued checks to Tews in the names of his purported foreclosing lenders.
MORAL
Very good. "A" for effort and the reward is 33 months in a federal prison.
FLORIDA SENDS HUSBAND AND WIFE ALONG WITH FIVE OTHERS TO FEDERAL PRISON
FACTS
U.S. District Judge Adalberto Jordan sentenced husband-and-wife defendants Evelyn Marrero and Jorge Bacallao, both of Miami, to eight years and four years of imprisonment, respectively, to be followed by terms of supervised release.
Marrero and Bacallao, the owners of the now-defunct J&E Universal Title Services Inc., pled guilty in December 2008 to conspiracy and wire fraud charges arising out of a multi-million dollar mortgage fraud scheme. They were charged in a multi-count indictment along with co-defendants Aivet Loarca, Marilyn De La Paz (a.k.a. Marilyn Martis), Daisy Gonzalez, Loaisa Rodriguez, and Elena Garman. Marrero, Bacallao and De La Paz (the third owner of J&E Universal) participated in fraudulent purchase and sale transactions of residential property as the title and closing agent through J&E Universal.
Marrero, Bacallao, and De La Paz conspired with Loarca and Gonzalez, who worked as mortgage loan brokers, to submit fraudulent applications for mortgage loans. The applications included materially false information about the borrowers' employment verification, income and deposit funds verification, and rent verification. As part of the transactions, the defendants used straw purchasers, including Rodriguez, or otherwise used stolen identities, which Garman helped obtain.
Following the lending institutions' approval of the applications, the institutions wire-transferred the loan proceeds to the defendants' title company for closing. The defendants regularly used J&E Universal as the title closing agent. Through J&E Universal, the defendants used the loan proceeds to pay creditors, themselves, and other co-conspirators.
In sum, from early 2005 through late 2007, the defendants participated in some or all of more than 30 real estate transactions in Miami-Dade County with funded loans totaling almost $13 million.
Judge Jordan has sentenced four of the defendants in this case, including Rodriguez, who received 24 months imprisonment on May 12th; Gonzalez, who received 30 months imprisonment on May 26th; De La Paz, who received 96 months imprisonment on May 28th; and Loarca, who received 72 months imprisonment on June 2nd. (usattysdfl6509)
MORAL
I would like you to notice the size of the prison terms. The meltdown of the economy and the recession are all being blamed on mortgage brokers doing false and/or bad loans not fit for the borrowers. The sentences are getting tougher (longer) and the federal prosecutors are now doing forfeitures as well as restitution. Like double the fine?
NEW ORLEANS MAN DRAWS 40 MONTHS IN FEDERAL PRISON FOR HOUSE FLIPPING SCAM
FACTS
CALVIN DAVIS was sentenced June 11, 2009 by the Honorable Martin L.C. Feldman to 40 months imprisonment pursuant to his plea of guilty to Conspiracy to Commit Mail Fraud, Making False Statements to Obtain HUD Insurance and Making False Statements in Income Tax Returns.
DAVIS purchased various properties, obtained fraudulent appraisals and arranged for straw buyers to purchase them. DAVIS then sent the straw buyers to Citywide Mortgage to obtain loans by using fraudulent employment and credit documents as well as false tax returns. These loans were approved by MICHELLE COCHRANE, a former underwriter at Citywide Mortgage. COCHRANE admitted at her guilty plea, that she participated in the house flipping scheme with DAVIS and others. COCHRANE pled guilty to approving fraudulent FHA/HUD loan applications for the straw buyers while employed at Citywide Mortgage. COCHRANE also admitted that after she approved the fraudulent loan applications, the loans were forwarded to the HUD offices in Denver. Based on the fraudulent applications, the Department of Housing and Urban Development insured the loans. Citywide then sold the loans to another mortgage company. Various properties eventually went into default and HUD became responsible for paying off those loans. Additionally, DAVIS failed to report the income he was generating from these various schemes on his income tax returns. DAVIS, who was on bond, was remanded into custody and will begin serving his sentence immediately.
Judge Feldman considered the cooperation provided to the government by DAVIS in imposing the custodial sentence. The defendant was all ordered to pay $1,018,449.00 in restitution to HUD and the Internal Revenue Service.
DAVIS is the fifth person to be sentenced for offenses stemming from this investigation. ROBERT GREEN, who pled guilty to Making False Statements in a HUD transaction and admitted that he prepared the fraudulent tax returns, was sentence to a probationary term. Three straw buyers, TIMOTHY FALLS, DENNIS ADDISON and DENNIS LEBLANC, who also pled guilty to Making False Statements in HUD Transaction, were also sentenced to probationary terms. MICHELLE COCHRANE, who pled guilty to Conspiracy to Make False Statements in a HUD transaction, and MICHAEL O'KEEFE, JR., who pled guilty to Making False Statements in a HUD transaction, are awaiting sentencing. (usattyedla61109)
MORAL
Note that he cooperated and he still drew 40 months in prison. The government because of the fallout of the fraud loans and the foreclosures and failing economy because of the foreclosures is tougher and tougher including now asking for forfeiture in addition to sentencing and restitution.
NEVADA CHANGES FORECLOSURE LAW BY FORCING LENDERS TO DO LOAN MODIFICATIONS EFFECTIVE JULY 1, 2009 (AB 149)
FACTS
Existing law sets forth procedures governing foreclosures on real property upon default. A trustee under a deed of trust has the power to sell the property to which the deed of trust applies, subject to certain restrictions. (NRS 107.080, 107.085)
AB 149 is effective July 1, 2009. Section 1 of this bill establishes additional restrictions on the trustee's power of sale with respect to owner-occupied housing by providing a grantor of a deed of trust or the person who holds the title of record with the right to request mediation under which he may receive a loan modification. Once mediation is requested, no further action may be taken to exercise the power of sale until the completion of the mediation.
Each mediation must be conducted by a senior justice, judge, hearing master or other designee pursuant to rules adopted by the Nevada Supreme Court, and a fee of not more than $85 per hour may be charged and collected for the mediation.
Section 2 of this bill also restricts the trustee's power of sale with respect to owner-occupied housing by revising the period in which a deficiency in performance or payment under the trust agreement may be made good before the trustee may exercise that power.
Section 3 of this bill restricts the trustee's power of sale with respect to owner-occupied housing by revising the manner in which service of notice that a person is in danger of losing his home must be made.
Section 4 of this bill authorizes the Nevada Supreme Court to adopt rules providing for voluntary mediation with respect to a homeowner who is not in default but is at risk of default.
MORAL
If you are a broker or loan officer, read this bill VERY CAREFULLY. YOU CAN HELP YOUR BORROWERS THAT ARE BEHIND OR MAY GET BEHIND IN THERE PAYMENTS TO RENEGOTIATE THE RE LOANS SO THAT THEY AHD THEIR CHILDREN DO NOT GET EVICTED THROUGH FORECLOSURE.
LAS VEGAS, EX-BROKER CHASED BY FEDERAL TRADE COMMISSION FOR DUMPED TRASH BIN CONTAINING BORROWER FINANCIAL INFORMATION
FACTS
Forty boxes of paperwork were found in a trash bin in December 2006 and the alleged owner of them is being dragged into court by the Federal Trade Commission. The agency is charging former mortgage broker Gregory Navone with violating the Fair Credit Reporting Act and rules governing the disposal of consumer information and records.
A neighbor discovered the boxes in a bin assigned to 811 S. Decatur, an office complex between Alta Drive and Charleston Boulevard. At the time, the building housed two companies registered to Navone: First Interstate Reality Inc. and BNG LLC. Those companies are now respectively listed as in default and having revoked licenses on the Nevada Secretary of State Web Site and Navone is no longer licensed as a broker with the state's Division of Mortgage Lending.
What had been treated as trash outside Navone's offices turned out to be "tax returns, mortgage applications, bank statements, photocopies of credit cards and drivers' licenses, at least 230 consumer reports, and other documents containing sensitive consumer information" collected by Navone's companies, according to the FTC complaint.
The complaint alleges he broke other rules regarding safeguarding sensitive consumer information, including keeping some of the information collected by his companies "in an insecure manner" in the garages of two of his homes.
The federal consumer protection agency is seeking penalties of not more than $2,500 for each violation of the disposal rules, though what that would add up to, if Navone is found guilty, is unclear.
In court filings, Navone denies the trash bin in question was publicly accessible and claims he does not know what kind of documents was found in the boxes because they were taken before he could examine the contents. The former mortgage broker says he was not in a position to "direct, participate or control" circumstances leading to the alleged security breach.
Of the 31 reported security breaches in banking, credit and financial industries, Navone's case is one of two that occurred at companies based in Nevada. The second reportedly occurred in Reno, where almost 30 people filed reports of fraud at Clear Star Financial Credit Union after discovering unauthorized charges on their debit cards, according to Identity Theft Resource Center. (lvsun61209)
MORAL
Think about it. $2,500 per violation (per file), so 50 files is $12,500 and counting if the bin was overflowing; 100 files is $25,000. Interesting thoughts: The federal people may be slow, but not slow because of lack of diligence. It takes time to interview the borrowers in the trash bin and validate the information and who it was given to so the borrower can be a witness in court. But the federal people are very good and rarely lose. So, do not mess with them, especially in this climate. I know of one other broker that allegedly did the same thing in Orange County, California. On February 28, 2009 it made the Orange County Register. On March 20, 2009 an accusation was filed against Paul Henry Reed, owner-broker of Seaview Financial as I predicted in February 2008. Give it one more year and here comes the FTC and then he really has problems.
PAST PRESIDENT OF A NEW JERSEY MORTGAGE COMPANY CAUSES IT TO GO BANKRUPT IN $139 MILLION FRAUD SCHEME
FACTS
Michael J. McGrath, Jr., the former president and director of U. S. Mortgage Corp., pleaded guilty on June 11, 2009 to mail and wire fraud and money laundering charges in connection with a $139 million fraud scheme that bankrupted the Pine Brook, N.J.-based company and its subsidiary, CU National Mortgage LLC. The guilty plea carries potential combined sentences of up to 30 years in federal prison.
Under his plea agreement, McGrath faces an actual sentencing range of between 150 and 240 months in federal prison. He also will have to pay restitution to the victims and has agreed to forfeit to the United States the contents of several bank and brokerage accounts and his interest in a Hoboken property. The plea agreement does not bind Judge Hayden, who must consult the advisory sentencing guidelines, but has discretion in imposing a sentence within, above or below the determined guidelines range.
Judge Hayden scheduled sentencing for Oct. 2, 2009. McGrath can be released on a $1 million secured bond and ordered home confinement with electronic monitoring until sentencing.
McGrath admitted that during January 2004 through Jan. 28, 2009, he conspired with several others to fraudulently sell loans belonging to various credit unions and use the proceeds to fund U.S. Mortgage's operations and his personal investments and investments he made on U.S. Mortgage's behalf. McGrath further admitted that the scheme started with the diversion of funds that should have been paid to various credit unions for mortgage loans they had made and authorized CU National to sell to Fannie Mae. McGrath explained that he began withholding these funds to help U.S. Mortgage address cash flow problems caused by losing investments in mortgage-backed securities he had made on the company's behalf.
McGrath further admitted that when U.S. Mortgage's financial condition continued deteriorating, he sold hundreds of mortgage loans to Fannie Mae without the knowledge and consent of the credit unions that owned the loans. All told, the scheme netted approximately $139 million. (usattynj61109)
MORAL
$139 million!! That is a lot of money. But he is looking in all probability at a minimum of 12.5 years to 20 years in a federal prison. I told you the federal prosecutors were getting tougher.
.
NEW YORK ATTORNEY GENERAL SUES MODIFICATION CORP. AND ITS PRINCIPAL SHAREHOLDER
FACTS
New York Attorney General Andrew Cuomo is going after what he believes are foreclosure rescue scams. He filed a civil complaint against American Modification Agency Inc. and its owner and president, Salvatore Pane Jr., for allegedly charging illegal up-front fees and consumer fraud. American Modifications, based in Uniondale, N.Y., calls itself a foreclosure rescue company. It operates in all 50 states. The AG's office says American Modification targets homeowners facing foreclosure by claiming it can save their homes, but often fails to provide the services promised. In a prepared statement AMA said it is compliant with state foreclosure assistance laws and regulations.
The New York AG's office has subpoenaed 14 other loan modification-related firms. Other large states that are investigating and filing charges against loan mod firms include California, Florida, and Georgia.
Additionally, the AG has subpoenaed records from 14 other loan modification-related companies including law firms. The 14 companies are: American Home Recovery Corp.; CloseMore Financial Corp.; Elite Results Group Inc.; FLM Law Center LLP, a.k.a. Federal Loan Modification Law Center and Federal Loan Modification; Hometown U.S.A. Inc.; Global Modifications Inc., a.k.a. the law office of Brett Margolin PC; Loan Modification Affiliate Exchange Ltd, a.k.a. LoanMAE; Nationwide Modification Agency Inc.; NMA Legal Services PC; Northeast Mortgage Services; People's First Financial Inc.; Raymond Lewis & Fitch Inc.; Settled For Less Inc.; and the Law Depot Inc., a.k.a. the Loss Mitigation Legal Network.
The subpoenas include requests designed to uncover, among other information, the companies' marketing strategies, representations made to customers regarding the services the companies provide and their success rates, fee structures, whether contracts are provided in accordance with the law and what, if any, services are actually performed. (Brokun61009, nmn61009)
MORAL
If you want to buck the system and do loan modifications have a good lawyer on your side that knows the area of law. Otherwise, you lose a source of protection and can get hurt. Monetarily that is. At least 15 companies in New York including the owner of American Modifications should be having somewhat upset stomachs. It does pay to advertise. The advertising has brought in the Attorney General of New York. Do you advertise for trouble?
THE INFORMATION CONTAINED HEREIN IS NOT LEGAL ADVICE.
AN ATTORNEY SHOULD BE CONSULTED IF YOU DESIRE LEGAL ADVICE.
Please contact Herman Thordsen toll free (888) 667- 8529.
