FACTS - Payments to Loan Originators Based on Mortgage Transaction Terms or Conditions under Regulation Z, 12 C.F.R. § 1026.36.
This Bulletin is regarding the payment of compensation to loan originators under Regulation Z, 12 C.F.R. § 1026.36 ("Compensation Rules").
Loan originator compensation rules were originally adopted by the Federal Reserve Board in September 2010 and covered institutions were required to comply with the provisions on April 6, 2011. Pursuant to Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act"), rulemaking authority for Regulation Z transferred to the Consumer Financial Protection Bureau "Bureau." In December 22, 2011, the Bureau issued interim final rules recodifying the provisions of Regulation Z.
Subject to certain narrow exceptions, the Compensation Rules provide that no loan originator may receive (and no person may pay to a loan originator), directly or indirectly, compensation that is based on any terms or conditions of a mortgage transaction. The Commentary to the Regulation clarifies that compensation includes salaries, commissions, and annual or periodic bonuses. The Commentary also states that the terms or conditions of a transaction include the interest rate, loan-to-value ratio, or prepayment penalty. Furthermore, the Commentary provides that compensation may not be based on a factor that is a proxy for a term or condition, such as a credit score, when the factor is based on a term or condition such as the interest rate on the loan. Finally, examples are also provided in the Commentary of when compensation is not based on a transaction's term or condition, such as basing compensation on the long-term performance of the loan and whether the consumer is an existing customer of the creditor or a new customer.
The Compensation Rules apply to qualified profit sharing, 401(k), and employee stock ownership plans (collectively, "Qualified Plans"). A financial institution can, consistent with the Compensation Rules, contribute to Qualified Plans for employees, including loan originators, if employer contributions to such plans are derived from profits generated by mortgage loan originations.
Under the Dodd-Frank Act, the Bureau must adopt final loan originator compensation rules by January 21, 2013, or the provisions are self-effectuating on that date. The Bureau anticipates issuing a proposed rule for public comment in the near future on the loan origination provisions in the Dodd-Frank Act.
The Bureau's view is that the COMPENSATION RULES PERMIT EMPLOYERS TO CONTRIBUTE TO QUALIFIED PLANS OUT OF A PROFIT POOL DERIVED FROM LOAN ORIGINATIONS. That is, FINANCIAL INSTITUTIONS MAY MAKE CONTRIBUTIONS TO QUALIFIED PLANS FOR LOAN ORIGINATORS OUT OF A POOL OF PROFITS DERIVED FROM LOANS ORIGINATED BY EMPLOYEES UNDER THE COMPENSATION RULES.
The Bureau has also received questions about how the Compensation Rules apply to profit-sharing arrangements/plans that are not in the nature of Qualified Plans. Many of the questions have been fact-specific and the Bureau does not believe it is practical to provide guidance in this Bulletin about such plans. We anticipate providing greater clarity on these arrangements in connection with a proposed rule on the loan origination provisions in the Dodd-Frank Act. (CFPB 2012-2, 2-2-12)
MORAL
In other words, contributions from a common profit pool to qualified profit sharing plans are allowed for mortgage loan originators but the "Bureau" declines to offer advice on other plans until later. OR do what you want and we will decide if you violated the law later. Isn't that nice?
FORGETTING TO NAME THE "CONTINUED DATE" OF A FORECLOSURE SALE IN A BANKRUPTCY PROCEEDING CAN VOID THE SUBSEQUENT SALE
FACTS
Margaret Kekauoha-Alisa (Kekauoha) refinanced her home with Ameriquest Mortgage Company. She defaulted on her loan 8 times and Ameriquest initiated foreclosure proceedings. Three days before the sale, Kekauoha filed for Chapter 13 bankruptcy causing the automatic stay of the sale to go into effect. The sale was postponed three times.
On the third time Ameriquest sent a legal secretary to postpone it to a fourth time. The secretary arrived at the time and place for the sale and asked several people if they were interested in the property. She then left without announcing the new postponement date. In December the sale took place and the property was sold. Kekauoha filed a complaint alleging the sale violated the automatic stay. The bankruptcy court agreed and voided the foreclosure sale. The Bankruptcy Appellate Panel reversed because of failure to give the new date, time and location of the sale.
On Appeal, the 9th Circuit Court of Appeals said . . .
Reversed again. There must be a public announcement made by the holder of the mortgage. The secretary failed to do so. Sale voided. (Kekauoha-Alisa v. Ameriquest Mortgage Co. (In re Kekaujcha-Alisa) U.S. Court of Appeals-9TH Cir. No. l 09-60019-3-26-12)
MORAL
While this is in the state of Hawaii, it also holds true in California and other states. Failure to re-notice date, time and location can fatally affect the sale causing the buyer's money to be tied up and not having ownership of the property and waiting months to get the money back. If you do it, do it right. Here they lowered the cost by sending the legal secretary and probably spent ten times as much curing the problem.
MORE ON THE INTERNAL REVENUE SERVICE AND HOW IT WILL TAKE NOTICE OF YOU AND YOUR TAXES
FACTS
For the most part, you as a taxpayer stand a low audit risk. The IRS audited less than 1.1% of all individual tax returns filed in 2010 or 1.4 million of the 141 million that were filed.
HOWEVER, 12.5% of taxpayers whose income was over $1 million faced an audit. Self-employed people who filed a Schedule C with gross receipts of over $100,000 faced an audit rate of about 4%.
WHAT TRIGGERS THE AUDITS? THE SEVEN RED FLAGS
1. Watch your Schedule C and stick to what are the real expenses. When cost of the goods you sell is 50% of the gross receipts you can trigger the audit. In one case the IRS found the business owner was reporting his expenses but about only half the revenue when audited. You need to look at BizStats.com for an idea what the numbers should look like reasonably. The IRS tells its agents to review this same site for average business costs.
2. Claiming large deductions will trigger an audit. Large depends on gross receipts vs. the deductions you claim. If you do it, be sure you have a receipt to prove it.
3. Do not try to claim a hobby as a business write off. As a business executive making $500,000 a year it is questionable that deducting your yacht expenses is a business charter.
4. Rental losses in current year should be able to show you spend 50% of your time or more devoted to the management of the rentals. This is a very hot item with the IRS so check with your tax agent when deducting real property expenses.
5. Taking 100% of car deduction expenses is an audit trigger. Very few people use their vehicles 100% of the time for business only. If you try you probably get an audit and that alone will cost you to have your accountant put it in order that is acceptable to the IRS.
6. Home office deductions are always a good flag for an audit. Considering the amount of taxes saved versus setting an IRS audit trigger, is it really worth the deduction when it does not give you that much? Again talk to your tax agent if you use the home office deduction.
7 Earned Income Tax Credits are looked at carefully. Especially for a social security number that does not exist in that household. (wsjlbus3-4-1-12)
MORAL
Save your receipts and call your accountant when in doubt. Remember, it is better to pay the accountant than to get stomach aches from the IRS audit. If you have questions call and if you do not have a good agent we are glad to recommend one. We can defend an audit but it is better to have your agent prepare the return and if necessary then have that person defend it.
TWO IN PHOENIX, ARIZONA PLEAD GUILTY TO MORTGAGE FRAUD OF OVER $5.3 MILLION
FACTS
On April 2, 2012 a Valley mortgage broker and her former associate have each admitted to conspiring to commit a multiple-transaction mortgage fraud that federal law enforcement calculates resulted in a loss to defrauded financial institutions of approximately $5,300,000. MICHELE MITCHELL, 45, OF GLENDALE, ARIZONA, ENTERED A GUILTY PLEA TO ONE COUNT OF CONSPIRACY TO COMMIT WIRE FRAUD IN FEDERAL COURT ON APRIL 2, 2012. JEREMY PRATT, 33, ALSO OF GLENDALE, HAD PREVIOUSLY ENTERED HIS GUILTY PLEA TO ONE COUNT OF CONSPIRACY TO COMMIT WIRE FRAUD ON JANUARY 13, 2012.
MITCHELL HELD HERSELF OUT TO BE A MORTGAGE BROKER, LOAN OFFICER, AND REAL ESTATE INVESTOR. SHE WAS PRESIDENT OF GOLDEN OPPORTUNITY INVESTMENTS, WHICH WAS LOCATED IN SCOTTSDALE, ARIZONA. PRATT OPERATED A CONSTRUCTION AND REMODELING COMPANY, ARIZONA COOLING CONTROL PLUS.
Both admitted that between May 2005, and February 2007, they conspired to recruit straw buyers with good credit scores to purchase residential properties for purported investment purposes. In order to qualify for mortgage financing, they had the straw buyers SUBMIT LOAN APPLICATIONS AND SUPPORTING DOCUMENTS THAT MISREPRESENTED THEIR INCOMES, ASSETS, LIABILITIES, EMPLOYMENT STATUS, AND INTENT TO OCCUPY THE PREMISES. At the close of escrow, Mitchell and Pratt obtained a portion of the loan proceeds as "cash back" to be used for mortgage payments and for their own personal enrichment.
Mitchell and Pratt each admitted that their fraudulent scheme resulted in the purchase of at least 17 residential properties by obtaining loans from financial institutions in the total amount of nearly $17 million. All 17 properties went into foreclosure when neither Mitchell nor the straw buyers made the necessary mortgage payments. The total amount of "cash back" fraudulently obtained by Mitchell and Pratt from these transactions was $2.46 million and federal law enforcement calculates the loss to the financial institutions, that is, the difference between the total loan amounts and the total sales prices obtained at foreclosure sales, at approximately $5.3 million.
A conviction for conspiracy carries a maximum penalty of five years in prison, a $250,000 fine, or both. Pratt's plea agreement provides that his sentence will not exceed 24 months. Mitchell's plea agreement contains no such restriction. Pratt is scheduled to be sentenced by Judge Teilborg on May 29, 2012. Mitchell is scheduled to be sentenced by Judge Teilborg on June 18, 2012. (usattyaz4312)
MORAL
And here comes Phoenix bringing up the rear from 2005. Seven year old loans and counting.
CHICO, CALIFORNIA MAN DRAWS 57 MONTHS IN FEDERAL PRISON FOR MORTGAGE FRAUD
FACTS
On MARCH 30, 2012 NICHE SAVON FORTUNE, 39, OF CHICO, CALIFORNIA another participant in a widespread 2007 Chico mortgage fraud scam was sentenced in federal court to FOUR YEARS AND NINE MONTHS IN PRISON.
He was sentenced for OFFERING HOMEBUYERS KICKBACKS FROM BUILDERS and submitting false mortgage documents to lenders to obtain loans. The day after the close of escrow, the HOMEBUILDER WOULD WRITE CHECKS AVERAGING $41,000 TO FORTUNE'S FRONT COMPANY, FORTUNE PROPERTY INVESTMENTS. The conspirators would pay the buyers up to $29,000 of the kickbacks and divide the remainder among themselves.
FORTUNE'S SISTER, KESHA DANINE FORTUNE HAYNIE, 41, OF CHICO, was convicted of the same crimes Wednesday after a six-day jury trial. Both defendants are in custody. Note the maximum sentence for her can be up to twenty years in a federal prison. (chcentrec33012)
MORAL
It would be interesting to see what the federal prosecutors did to the builders, wouldn't it?
FORMER REALTOR AND RADIO SHOW HOST IN SAN FRANCISCO, CALIFORNIA GETS 15 YEARS IN PRISON FOR MORTGAGE FRAUD
FACTS
On April 6, 2012 EDWARD PARADA, 33 of San Francisco, California a former realtor and Christian radio show host was SENTENCED TO 15 YEARS IN PRISON for a mortgage fraud scheme targeting Spanish speaking homeowners that totaled more than $2 million, according to the San Francisco District Attorney's Office. Parada pleaded guilty Feb. 17 to 24 counts of fraud affecting a total of 31 victims.
Parada, who was a former realtor and pastor had hosted a paid Spanish-language radio show that dealt with real estate and religion, contacted his victims through his work in real estate and his radio show. He maintained an office in the Outer Mission district at 5700 Mission St.
Parada offered to assist victims, many of whom were struggling with mortgage payments, in buying, selling or refinancing a home and persuaded them to give him money, which he failed to return, according to prosecutors.
In some cases Parada gained titles to the homes, although it is not clear that victims knew he was doing so, or refinanced them and withdrew a large amount of equity, which he pocketed, without the victims' knowledge. The cases against three others allegedly involved have not been resolved yet. (cbs4612)
MORAL
Greed will do it every time. When the person complains, do not ignore them. At least consult your attorney. The attorney may advise giving the money back as the best solution. This is a lot less expensive than fighting a lawsuit.
SANTA CLARA COUNTY, CALIFORNIA CHARGES PAKISTANI COUPLE WITH LOAN MODIFICATION FRAUD – COUPLE FLEES THE COUNTRY
FACTS
SAMAN HASNAIN EASILY TOOK FIRST PLACE IN THE 2008 MRS. PAKISTAN WORLD BEAUTY PAGEANT. It has also been alleged that the same physical assets that snared Hasnain that top title also helped her lure SOUTH BAY HOMEOWNERS INTO A LOAN MODIFICATION SCAM SHE AND HER HUSBAND JAWAD OPERATED FROM 2008 THROUGH OCTOBER 2010, PROSECUTOR VICTOR CHEN CONTENDS.
SAMAN'S STRIKING APPEARANCE WAS CRUCIAL, CHEN SAID, because the couple didn't know their victims and had to make a good first impression. They allegedly attracted homeowners by word of mouth and through fliers passed out at ethnic supermarkets after the housing market tanked, according to Chen.
NOW THE SANTA CLARA COUNTY DEPUTY DISTRICT ATTORNEY HAS CHARGED THEM WITH ALLEGEDLY RIPPING OFF 17 PEOPLE -- just a fraction of the 80-100 families he says they defrauded. The Hasnains each face 19 felony counts of conspiracy to commit grand theft in the loan-modification scheme, and Jawad also has been charged with nine additional counts of felony grand theft for allegedly enticing victims from 2006 through July 2010 into investing in a fraudulent 10-unit condominium development in Fremont.
THERE IS ONE BIG PROBLEM: Earlier this month (March), the couple allegedly fled with their two young sons to LAHORE, PAKISTAN -- a country that has no extradition arrangement with the U.S.
In the loan-modification scam, Chen said, the couple allegedly charged homeowners at least $4,500 and often more to renegotiate their mortgages with banks. The couple allegedly promised to refund the money if they failed to get the loans modified. To show their sincerity, the payments were placed in an escrow account. However, allegedly buried in the fine print of the contracts was a provision allowing Jawad to empty the escrow account, Chen said. Jawad used the proceeds from the loan-modification and investment scams to buy plastic surgery for Saman, as well as to pay for his Mercedes and the mortgage on the $2.2 million house they own in the Almaden Hills, the prosecutor said.
Chen has allegedly charged the couple with multiple counts of grand theft in connection with the loan modification scheme because he said they made no bone fide effort to get the loans modified and never refunded the money despite repeated pleas. It became illegal for anyone in California to collect advance fees for loan-modification services in October 11, 2009.
Jawad faces a maximum of 19 years and four months in prison if tried and convicted by a jury of his peers. Saman, at least four years. (sjmercnws32911)
MORAL
Remember, they are innocent until proven guilty in a court of law. But since they have allegedly fled to Pakistan which allegedly has no extradition will that ever happen?
MINNESOTA MAN GETS 45 MONTHS IN FEDERAL PRISON FOR $13 MILLION MORTGAGE FRAUD
FACTS
On March 30, 2012 Federal Judge Ann D. Montgomery sentenced ERICVAN ANTHONY MCDAVID, 37, of Savage, Minnesota TO 45 MONTHS IN FEDERAL PRISON for participating in a $13 million mortgage fraud scheme that involved no fewer than 25 properties in Prior Lake, Savage, and Minnetonka, among other Minnesota communities. He had pleaded guilty on January 26, 2011.
In his plea agreement, McDavid admitted that between April of 2005 and February of 2009, he conspired to obtain loan proceeds fraudulently by making false representations and promises as well as by withholding material information. During that time, McDavid was either an owner or co-owner of several businesses, including EVM PROPERTIES, SKYY REALTY AND UNIVERSAL, INC., through which he bought, sold, and managed real estate. To carry out this fraud scheme, McDavid recruited "straw buyers" to purchase selected properties by promising them payments of $15,000 to $52,000 per transaction.
Once a buyer agreed to purchase a particular property, McDavid provided that buyer with funds to put toward the purchase, thereby misleading the lender into believing that the buyer actually had a financial interest in repaying the loan, when, in reality, that was not the case. McDavid then produced or caused the production of false loan applications on behalf of the buyers. Those applications overstated the buyers' assets and employment status. Because of the false applications, mortgage loans were approved in no fewer than 25 real estate transactions, with total loan proceeds amounting to approximately $13 million. While those proceeds were intended to pay for the properties and other transaction-related expenses, McDavid admittedly used portions of them to benefit himself personally.
Ultimately, the properties fell into default and ended up in foreclosure and were sold for a total of about $4 million, resulting in a loss due to this scheme of about $9.2 million.
On April 29, 2011, McDavid's sister, Renee Lynise McDavid, age 40, of Brooklyn Park, was sentenced to three years of probation on one count of conspiracy to commit wire fraud. She was charged on January 19, 2011, and pleaded guilty on January 25, 2011.
In her plea agreement, Renee McDavid admitted participating in the scheme from 2006 through 2008. In her capacity as a licensed real estate agent and mortgage broker, she was responsible for losses incurred in five of the 25 property transactions noted above. In those instances, she entered false information on loan applications so straw buyers would qualify for mortgage loans they otherwise would not be eligible to receive. The lenders incurred a loss of approximately $768,000.
Ericvan McDavid's two other co-defendants were sentenced on July 12, 2011, each on one count of conspiracy to commit wire fraud. LARRY AFRICANUS HUTCHINSON, AGE 41, OF ST. PAUL, WAS SENTENCED TO 21 MONTHS IN PRISON, AND JERONE IAN MITCHELL, AGE 36, OF MINNEAPOLIS, WAS SENTENCED TO 12 MONTHS AND ONE DAY IN PRISON. They pleaded guilty in September of 2010. (minnetoka33012)
MORAL
I would like you all to note that the events started in 2005 some 7 years ago and based upon the sentencing since we do defend quite a few of these cases, I would venture a guess that the sister cooperated greatly with the FBI. What do you think?
THREE FORMER NEVADA REAL ESTATE PROFESSIONALS CONVICTED AND SENTENCED TO FEDERAL PRISON
FACTS
On March 23, 2012 three former real estate industry professionals were sentenced to federal prison terms today for their involvement in a Las Vegas mortgage fraud scheme that caused over $52 million in losses to federally-insured banks, announced Daniel G. Bogden, United States Attorney for the District of Nevada.
EVE MAZZARELLA, 34, OF SAN DIEGO, WAS SENTENCED THE MORNING OF MARCH 23, 2012 TO 14 YEARS IN PRISON. HER EX-HUSBAND, STEVEN GRIMM, 49, OF LAS VEGAS, WAS SENTENCED THE SAME AFTERNOON TO 25 YEARS IN PRISON, AND MELISSA BEECROFT, 32, OF LAS VEGAS, WAS SENTENCED THIS AFTERNOON TO THREE YEARS IN PRISON. ALL THREE WERE ALSO ORDERED TO PAY APPROXIMATELY $2.3 MILLION IN RESTITUTION. MAZZARELLA AND BEECROFT WERE PERMITTED TO SELF-REPORT TO FEDERAL PRISON BY JUNE 29 AND JUNE 15, 2012, RESPECTIVELY; GRIMM WAS REMANDED TO CUSTODY.
Mazzarella, Grimm, and Beecroft were convicted of conspiracy and fraud charges in December following a 37-day jury trial. Eight other defendants charged in the scheme pleaded guilty before trial.
"Over 200 Las Vegas properties valued at over $107 million were fraudulently purchased in this case," said U.S. Attorney Bogden. "The losses to the banks were over $52 million. This is the greatest number of properties and largest loss amount of any mortgage fraud case charged in Nevada. Ms. Mazzarella, Mr. Grimm, and Ms. Beecroft will now join the over 140 other persons who have been convicted of mortgage fraud offenses in Nevada over the last four years and are serving time in federal prison."
The evidence presented by the government at trial indicated that Eve Mazzarella and her husband Steven Grimm controlled and operated numerous Nevada limited-liability companies that conducted business in Las Vegas. MELISSA BEECROFT WAS RESIDENT AGENT AND MANAGER OF SECURED MORTGAGE SERVICES LLC, ALSO REGISTERED IN NEVADA.
The object of the conspiracy was to obtain money and property by causing false information to be placed in the mortgage loan applications of straw buyers. It is alleged that the straw buyers were paid to participate in the conspiracy. After the mortgage loans were funded, defendants Grimm and Mazzarella caused title and escrow companies to disperse a portion of each loan to one of their limited liability companies and caused mortgage brokers, loan officers, and others to remit a portion of their commissions and fees to Grimm and Mazzarella. Once Grimm and Mazzarella obtained control over a property, they re-sold the same property to another straw buyer at an inflated price. Grimm and Mazzarella also concealed receipt of the monies they obtained through this scheme by causing disbursements to be made to shell companies under their control and by moving money between multiple accounts. Beecroft assisted in the scheme as a mortgage broker, loan officer, and loan processor on the majority of the fraudulent mortgage loan transactions.
GRIMM AND MAZZARELLA ENGAGED IN APPROXIMATELY 450 STRAW BUYER TRANSACTIONS INVOLVING APPROXIMATELY 227 PROPERTIES WITH A TOTAL PURCHASE PRICE OF OVER $107 MILLION. Grimm and Mazzarella defaulted on mortgage payments on many of the loans, which caused the properties to go into foreclosure. Almost all of the 227 properties purchased by the defendants are in default, causing losses to the banks estimated at more than $52 million. (usattylasvegasnv3-23-21)
MORAL
Makes an interesting story, does it not? You should read the rest of it by using Google.
FIFTH NEW JERSEY MAN PLEADS GUILTY TO $40.8 MILLION MORTGAGE FRAUD SCAM
FACTS
On April 5, 2011 WILLIAM BROWN, 60, OF NEWARK, NEW JERSEY, PLEADED GUILTY to an information charging him with conspiracy to commit wire fraud and conspiracy to commit money laundering. He entered his guilty plea before Senior U.S. District Judge Joseph E. Irenas in Camden federal court. Brown recruited "straw buyers" for his co-conspirators to purchase oceanfront condominiums overbuilt by financially distressed developers in Wildwood Crest, New Jersey, premier real estate in vacation destinations in Georgia and South Carolina, and properties in New Jersey owned by financially distressed homeowners facing foreclosure. Brown's co-conspirators caused fraudulent mortgage loan applications and supporting documents to be submitted to mortgage lenders in the straw buyers' names, attributing to them inflated income and assets in order to induce the mortgage lenders to approve the loans.
Once the loans were approved and the mortgage lenders sent the loan proceeds in connection with the real estate closings on the properties, Brown's co-conspirators took a portion of the proceeds from the fraudulent mortgage loans. Brown also admitted that he and his co-conspirators laundered the proceeds of the mortgage fraud by having some of those proceeds transferred to the recruiters and straw buyers. Brown received $96,000 for his role.
CHARLES HARVATH, 33, OF LODI, NEW JERSEY, AND STEPHEN F. CORBA, JR., 36, OF FARMINGDALE, NEW JERSEY, PLEADED GUILTY on July 19, 2011 and August 3, 2011, respectively, to informations charging them each with one count of conspiracy to commit wire fraud and one count of conspiracy to commit money laundering. Harvath, Corba, and their co-conspirators located distressed properties, recruited straw buyers, and created false documents in order to inflate the straw buyers' qualifications as part of the scheme. Sentencing for Harvath is currently scheduled for June 25, 2012; sentencing for Corba will be set by the court.
JOHN SIUSZKO, 56, OF WHARTON, NEW JERSEY, AND MICHAEL WILLIAMS, 34, OF JERSEY CITY, NEW JERSEY, also pleaded guilty on July 27, 2011 and August 16, 2011, respectively, to informations charging them with conspiracy to commit wire fraud. Siuszko and Williams served as straw buyers, who caused lenders to release almost $980,000 and $632,000, respectively, based on fraudulent mortgage loan applications. Sentencing for Siuszko is currently scheduled for June 5, 2012, and sentencing for Williams is scheduled for June 7, 2012.
The wire fraud conspiracy charge to which Brown pleaded guilty carries a maximum potential penalty of 30 YEARS IN PRISON AND A $1 MILLION FINE. The money laundering conspiracy charge carries a maximum potential penalty of 10 years in prison and a $250,000 fine. In addition, Brown agreed to forfeit $96,000, representing the amount of proceeds obtained as a result of the offense. Sentencing for Brown is currently scheduled for July 19, 2012. (usattynj4512)
MORAL
The end is not yet in sight.
THE INFORMATION CONTAINED HEREIN IS NOT LEGAL ADVICE.
AN ATTORNEY SHOULD BE CONSULTED IF YOU DESIRE LEGAL ADVICE
