REVERSE DECEMBER 2010 / JANUARY 2011
The SAFE Act: Will it Serve its Purpose? The industry anxiously awaits the changes that come with the passage of the SAFE Act. John Smaldone
10 ways to become the
“Go -To” persoN
new look year
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Moving Forward in Rever se
social security 24
The SAFE Act: Will it Serve its Purpose? 18 The industry anxiously awaits the changes that come with the passage of the SAFE Act.
2010...And We Thought 2009 Was Rough? 24 Finding the good in the year behind us.
Unwinding the Property Tax and Insurance Obligation
Spotlighting the concerns that lenders and brokers are facing.
Taxation on Foreclosure - Part III
Determining the amount of debt forgiven.
James E. Veale l
the The Report 7, 9 Ask the Underwriter
The Perspective 12
Core The Advisor 14
The Resources 36 The Last Word 37
4 | TRR
Meet the Team Publisher
Aman Makkar Your greatest strength is knowing your greatest weakness.
Letter from the Editor
Emily Vannucci “You’re trying too hard... try less.”
Kersten Wehde I can’t read a menu, text or wedding invitation without proofreading it. With 2010 coming to an end, I’ve taken some time to both reflect on all that has happened this year and prepare for the year ahead. Here at The Reverse Review we have been listening to your advice, suggestions and comments, and we took them to heart while redesigning the entire publication. After many sleepless nights and research overload, we are thrilled to finally present a new layout, design and overall feel for the new year! The staff here at TRR weren’t the only ones who have been hard at work; our lineup of contributors for the Dec/Jan 2011 issue have stepped up to the plate with a selection of exciting articles and columns.
As you turn the pages to the Essentials, you will find all our informational, opinionated and sometimes eyebrowraising articles, as well as the feature article for each issue. John Smaldone, who wrote this month’s feature, has contributed an article that he has been putting together for some time. The article highlights a lot of what is not talked about within the industry and brings to light some topics people aren’t quite aware of. As a seasoned professional within the mortgage industry, he has seen all of the highs and lows and shares it in “The SAFE Act: Will it Serve its Purpose?” John put a lot into this article and it certainly shows.
To make it easier on you, we’ve divided these articles into two sections: the Core and the Essentials. Within the Core, you’ll find all of our monthly columns, including ones like the Conversation, written by Dave Bancroft. This month he puts his humorous and witty HECM spin on ‘Twas the Night Before Christmas. The Core also debuts a new column this issue called the Advisor, which will be answering your industry-related marketing questions on a regular basis.
While I believe that nothing can ever be perfect, I still like things to be as close as possible. So if there is something you see that we can improve upon, please let us know! The time spent with The Reverse Review should be your time away from work, emails and the phone – your time to sit back and enjoy the experience of reading a magazine. Please enjoy all of our hard work that went into the Dec/Jan 2011 issue.
National Accounts Manager David Peck Changing the industry... one ad at a time.
Brett Varner “He who spends too much time looking over their shoulder, walks into walls.”
Advertising Information phone : 858.832.8320 e-mail : email@example.com Subscriptions and Editorial Content phone : 858.217.5332 e-mail : firstname.lastname@example.org website : reversereview.com
Editor-in-Chief emily vannucci
Tray-Sea Knight I don’t even know how to spell my own name. Sorry, Kersten.
Printer The Ovid Bell Press
Until next time,
© 2010 The Reverse Review, LLC. All rights reserved. The Reverse Review, LLC is a California limited liability company and is the publisher of The Reverse Review magazine. Reproductions or distribution of any materials obtained in the publication without written permission is expressly prohibited. The views, claims and opinions expressed in article and advertisement herein are not necessarily those of The Reverse Review, its employees, agents or directors. This publication and any references to products or services are provided “as is” without any expressed or implied warranty or term of any kind. While effort is made to ensure accuracy in the content of the information presented herein, The Reverse Review, LLC is not responsible for any errors, misprints, or misinformation. Any legal information contained herein is not to be construed as legal advice and is provided for entertainment or educational purposes only. Postmaster : Please send address changes to The Reverse Review, 16745 W. Bernardo Drive Suite 450 San Diego, CA 92127
Feature Article l
The SAFE Act: Will it Serve its Purpose? pg 18
The Conversation, pg 16
Dave Bancroft, Founder and former President of Omni Reverse Financing Inc., is an industry expert in the origination of reverse mortgages, FHA and VA government loans. Dave founded Omni Home Financing in 2002 in order to specialize in government lending and is now one of the largest originators of HECM reverse mortgages in the country. 949.355.4653| email@example.com l
2010...And We Thought 2009 Was Rough?, pg 24
Founder of LoanWell America, Inc., Michael Banner is one of few reverse mortgage professionals accredited to teach continued education classes to CFPs, CPAs, attorneys, and insurance agents. Michael has been interviewed by The Wall Street Journal, Tampa Bay Business Journal, and has appeared on the FOX Business Network. 877.753.1705 | Michael.Banner@loanwellamerica.com l
John Smaldone, founder of Taylor, Bean and Whitaker and former Senior Vice President of TransLand Financial Services Reverse Mortgage Divisions, is the Executive Vice President of Hanover Financial Services, a consulting firm primarily in the reverse mortgage industry. With 42 years of mortgage banking experience, 10 years being in reverse mortgages, John intends to remain in the reverse mortgage area of the business taking on long term consulting assignments. firstname.lastname@example.org
6 | TRR
Unwinding the Property Tax and Insurance Obligation, pg 28
Lori Eshoo is President and CEO of National Tax Search LLC (NTS), a Womenâ€™s Business Enterprise (WBE) based in Chicago and established in 1996. NTS provides comprehensive commercial and residential property tax management, tax certification and sales tax payment processing services. 312.233.6440 | email@example.com
The Advisor, pg 14
Sue Haviland is co-founder of reversemortgagesuccces.com. She has been in the mortgage industry for over 25 years. Unlike many others, Sue originates reverse mortgages each and every day! If you would like to profit from the largest niche to ever hit the mortgage industry grab their free course and profit producing tips at reversemortgagesuccess.com l
The Last Word, pg 37
Shannon Hicks is VP of Product Development at Reverse Fortunes, Inc. He draws from his experience as a reverse mortgage originator and prior work in the financial services industry. He has spoke nationally at NRMLA events and is also host of Reverse Fortunes Weekly, the nationâ€™s only weekly podcast for reverse mortgage professionals. 800.805.9328
The Reverse Review December 2010 /January 2011
Top Lenders Report
Wells Fargo MetLife Bank NA Bank Endorsement Endorsement 1783 579
Rank / Lender
Bank of America NA
One Reverse Generation Mortgage LLC Mortgage Endorsement Company 338 Endorsement 131
Rank / Lender
1ST AAA REVERSE MORTGAGE
SECURITY ONE LENDING
M AND I MARSHALL AND ILSLEY
URBAN FINANCIAL GROUP
ASPIRE FINANCIAL INC
MONEY HOUSE INC
FIRST MARINER BANK
GUARDIAN FIRST FUNDING GROUP L
SENIORS REVERSE MORTGAGE
GENWORTH FINANCIAL HM EQUITY
ENVOY MORTGAGE LTD
FINANCIAL FREEDOM ACQUISITION
AMERICAN ADVISORS GROUP
STAY IN HOME MORTGAGE INC
PNC REVERSE MORTGAGE LLC
SENIORS FIRST MORTGAGE COMPANY
NET EQUITY FINANCIAL INC
WILMINGTON SAVINGS FD SOCIETY
UNITED SOUTHWEST MORTGAGE CORP
ROCKLAND TRUST CO
SUNTRUST MORTGAGE INC
TRADITIONAL HOME MORTGAGE INC
IREVERSE HOME LOANS LLC
CHERRY CREEK MORTGAGE CO INC
EQUIPOINT FINANCIAL NETWORK
HOME SAVINGS OF AMERICA
NEW DAY FINANCIAL LLC
MONTGOMERY MORTGAGE INC
MIDCONTINENT FINANCIAL CENTER
OPEN MORTGAGE LLC
SENIOR MORTGAGE BANKERS INC
PRIMELENDING A PLAINSCAPITAL CO
FIRST NATIONAL BANK
UNIVERSAL LENDING CORPORATION
M AND T BANK
UPSTATE CAPITAL INC
GREAT OAK LENDING
AUGUSTA MORTGAGE INC
ROYAL UNITED MORTGAGE LLC
HARVARD HOME MORTGAGE INC
PRIORITY MORTGAGE CORPORATION
UNITED NORTHERN MORTGAGE BANKERS
TRR | 7
the Contributors l
John K. Lunde
The Report, pg 7, 9
John K. Lunde is President and Founder of Reverse Market Insight, Inc., a performance data analysis and consulting firm specializing in the reverse mortgage industry. RMI clients include eight of the top 10 reverse mortgage lenders plus investors, servicers and vendors to the industry. 949.429.0452 | rminsight.net
The Advisor, pg 15
Alain Valles, CRMP, is president of Direct Finance Corp, Hanover, MA. He has obtained the CSA designation, a masters in Real Estate from MIT, an MBA from the Wharton School, and graduated summa cum laude from the Univ. of Massachusetts. Alainâ€™s mission is to improve the quality of life through responsible financing. 781.878.5626 | firstname.lastname@example.org
Brett G. Varner
Ask the Underwriter, pg 10
Ralph Rosynek has been The Reverse Review Ask the Underwriter for more than two years. He is an industry HECM consultant and trainer, leveraging many years of executive and owner skills and knowledge in the reverse mortgage space including HECM Direct Endorsement credentials. Ralph is currently a seated Director for NRMLA and co-chairs the Professional Development Committee. 708.774.1092 | email@example.com
The Perspective, pg 12
Brett G. Varner is the newly appointed News Editor for reversereview.com. He has served the mortgage industry for 10 years in leadership capacities in sales, marketing and operations. His unique and knowledgeable perspective is focused on developing useful content and strategies in a forum of open and lively debate. firstname.lastname@example.org
8 | TRR
James E. Veale
The Advisor, pg 14
Brian Sacks is co-founder of reversemortgagesuccces.com. He has been in the mortgage industry for over 25 years. Unlike many others, Brian orginates reverse mortgages each and every day! If you would like to profit from the largest niche to ever hit the mortgage industry grab their free course and profit producing tips at reversemortgagesuccess.com
Taxation on Foreclosure, pg 32
James E. Veale is a Senior Vice President at Security One Lending, Inc. Jim is also a California CPA and real estate broker with a masterâ€™s degree in business taxation from the University of Southern California.
The Reverse Review December 2010 /January 2011
INDUSTRY SUMMARY Retail Endorsement Growth
September Endorsements Retail and Wholesale Volumes
Wholesale Endorsement Growth
- Reverse Market Insight
Total Endorsement Growth
We already knew that September was a down month for endorsements in the industry overall, but now we can look at the tally in a bit more detail.
* Figures Above Reflect Change from Prior Month
Trailing Twelve Month Endorsements
After several months of the broker/wholesale channel losing the volume battle, the down market showed less decline (-4%) than the retail/direct channel (-14%). One month isn’t going to change the tide of regulation
and resulting transformation of some brokers consolidating into direct
lenders while others become loan officers at larger institutions. That said, brokers are nothing if not scrappy and we’ll see more than a few stay on the broker/wholesale side as it transitions to TPO.
We’ve also been closely following the breadth of our industry’s recovery
from the May volume lows, as measured by lenders above/below their
May volume figures. We’ll be the first to caution that normally you
shouldn’t look at individual months as especially important when using
endorsement data, but in this case the decline and recovery have each
been severe enough and long enough to make for interesting comparisons.
0 10 11 12 1 2 3 4 5 6 7 8 9 Retail
Wholesale *Numbers Represent Months
RETAIL UNITS CHG%
Among the top 10 lenders specifically, several companies seemed to lag behind in increasing loan volumes, while others leaped forward.
As you can see, nine of the top 10 lenders have increased volume since
May, with several showing dramatic increases. As of just two months ago, only five lenders had increased volumes at an almost identical industry
volume (1.4% higher in September). Whatever your thoughts about each of these lending leaders, we can all agree that it doesn’t progress our
industry forward to see volume declines wash out major lenders from our business. g
TRR | 9
The Reverse Review December 2010 /January 2011
ask the Underwriter then took a deep breath and read the message again. “Thought you might
want to have this before you leave for the holidays,” my assistant wrote.
And there it was, the 2011 desk calendar.
In my rush to finish all of those last-minute items on my checklist before setting out
to enjoy the holidays, I completely forgot
that upon my return, the new year will be under way.
A second wave of reality soon resulted, as
the arrival of this calendar gave way to the dreaded new year’s resolution thoughts that most of us experience at this time
of the year. Rather than procrastinate, I decided to take action.
Recalling the guilt I experienced as I failed each of my 2010 resolutions, I
decided to alter my strategy for 2011
A Different Strategy for 2011 Ralph Rosynek
Yes, without warning, it happened one morning. Such a
kind and thoughtful message attached to
a jolt of reality. I stared at it for a moment,
10 | TRR
and concentrate my efforts in the area of
improving my reverse mortgage skills and knowledge. Pen in hand, I wrote the word “IMPROVEMENT” in the box of the first day of each month for the entire year.
You see, my only 2011 resolution is to review my list of actions thatwill improve my ability to achieve and be s u c c e ssf u l .
My thought process includes: Personal Education
While licensing and regulatory/legislative requirements have created specific
guidelines to continue participating
in offering the product, it is important
that once these minimums are met, we
each continue to participate in accessing available education situations that
challenge our ability to improve beyond those minimal requirements. Customer Education
Sharing knowledge is crucial to improving market share and new customer efforts. Participating in meetings, events and
various forms of media communication to showcase reverse mortgages and provide direct access to product information and availability is a tremendous benefit to those individuals participating in the transaction or seeking information to become a customer.
Best Business Practices
Knowing well what constitutes a best
business practice and adhering to a code of how we conduct our daily business objectives is key to improving the
customer experience as well as raising
the level of professionalism within the industry.
Quality of Work Product
Producing a quality work
product throughout the entire
process is an important component
to a successful transaction and satisfied customer. Extra attention to detail and
communication improves the efficiency of all participants in the transaction.
Keeping all participants in
the transaction informed and
staying on top of the transaction
will also improve its success, as well as the efficiency in which we are able to provide service to the customer.
to the reverse mortgage product continues
approach to improving your skills and
borrowers. I believe a focused concentration
I believe adopting a “sum of the parts” knowledge is a long term-success strategy. A wider perspective, gained through sharing and participating in the reverse mortgage
space, will reward the commitment of extra
time spent in many aspects of your personal efforts as you continue to provide service.
Pen in hand, I wrote the word “IMPROVEMENT” in the box of the first day of each month for the entire year.
Monitoring and Adjusting
Evaluating your progress and performance through feedback and reflection on issue
resolution in prior transactions will improve the ability to provide a higher level of
service and greater ability to achieve going forward.
2011 will no doubt present another handful
to address the needs of today’s eligible
on skills and knowledge is a tremendously defensive position to maintain given the implementation of new and/or revised legislation, regulation, guidelines and
definition criteria we will experience in the coming months.
I wish you the best of health, happiness, success and IMPROVEMENT for 2011 as we turn the page, and hope that in sharing you will consider a less guilt-ridden approach to your new year’s resolution…chances are your greater efforts will burn off those 10 pounds anyway! g
of opportunities and challenges as access
TRR | 11
The Reverse Review December 2010 /January 2011
the Perspective participants at the annual NRMLA
mass consolidation and the end of the small
outlook for the coming year was cautious
who are seeking to grow, these challenges
conference in New Orleans, the common
optimism. Generally, most people I spoke to felt that 2011 is going to be a better year than 2010, but there are several
A big concern is the status of the housing
environment. As the housing market begins
see further dips in 2011 before leveling
off and rebounding toward 2012, fallout from value issues looms as a major
issue. Strengthening resources, tools and skills in the initial estimates of home
values continues to be a major focus for
to recover and the size of the qualifying
population continues to grow, combined
with increased recognition of this product as a viable financial tool in retirement
planning, the potential of this industry will attract new competitors. It is just a matter of time.
When the dust of the recession settles and
support for their opinions that will sway
will remain true: Third-party originators
increasingly cautious underwriters and investors.
The rapidly changing regulatory
environment also presents interesting
12 | TRR
industry is a product of the larger economic
originators. At the same time, appraisers work to find the level of detail and
As I look to 2011, I have been thinking of the stories I am most interested in watching unfold. Talking with industry
targets for acquisitions.
Contraction in the reverse mortgage
analysts predicting that home values will
Brett G. Varner
become marketing tools when approaching
market. With a growing number of
The Small Business Battle for Survival
business broker in 2011. For some lenders
storylines. As the federal and state governments continue to use new
regulations to root out undue risk and restore confidence in the mortgage
industry, there is increased scrutiny on the reverse mortgage sector and
perceived potential abuses. With the
launch of the new Consumer Financial
Protection Agency and the changing tide in Washington, most people agree that
keeping up with the ongoing changes will
continue to keep compliance officers up at
the energy of growth rekindles, one fact
(aka brokers) will continue to be a viable and powerful force in this industry. The truth of the matter is that brokers create efficiency and reach that lenders will
never be able to fully replicate. Of course, bearing more of the responsibility over the originators they sponsor, lenders
will closely manage the quality of loans
provided from those sources. More than likely, lender sponsor guidelines for
approval will ball fairly close to the current requirements for FHA authorization.
Successful brokers have always been an innovative and entrepreneurial force in
the mortgage industry and they will find opportunity on the bumpy road ahead.
The application of compensation rules
For me, however, the most intriguing
also find ground in common sense before
story-line for 2011 is the business makeup of the reverse mortgage industry. There has been much talk about the change in FHA authorization and originator
compensation changes that will lead to
that are rumored to doom the broker will taking effect in April. The primary goal behind these rules is transparency and
fairness to the consumer. It is primarily
about making it clear to the consumer what they are paying for, while also making sure
that originators are not over-incentivized
to increase costs, loan amounts or interest
rates beyond what would be customary in a competitive environment.
The wholesale leaders report from Reverse Market Insight continues to show an
industry that is evenly split between retail
and wholesale loan production. Of the top 10 lenders in the industry, only two have
retail channels that are sizably larger than
their wholesale. In both cases, wholesale is not a focus of their business models.
In any case, this is a story with much
intrigue for the reverse mortgage industry and will be watched from every corner. I
look forward to hearing your perspective as
we follow it closely on reversereview.com. g
You’re very own appraiser
You’ve asked &
who is willing and able to answer any question you
throw his way. This spring, The Reverse Review will
debut Ask the Appraiser,
a monthly column fielding many of your unanswered
appraisal - related questions.
Email questions to email@example.com Look for your answer in an upcoming issue.
ORNEY A TT
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Paul N. Lovegrove PC Representing lending institutions for reverse closings for over 15 years
631.669.4370 plovegrove@AttorneyTrustReview.com • www.AttorneyTrustReview.com TRR | 13
The Reverse Review December 2010 /January 2011
the Advisor suggested taking him to the emergency room just to get it all checked out.
10 ways to become THE “Go-To” Person *Try a few at first, but don’t do them all at once. Most
We got him up and dressed but he didn’t
importantly, you cannot be a fake “go-to“ person. You must
look good. As we were helping him down the stairs, he passed out. I mean really
passed out - his eyes rolled into the back of his head and he was not responsive.
Naturally we called 911 and an ambulance
be an expert and you must produce good results.
Write articles for local publications about senior challenges and how a
reverse mortgage might resolve the
problems. Incorporate success stories of your own.
After getting him stable, the EMTs told
us they were taking him to a particular hospital, Sinai, in Baltimore.
THIS WAS NOT THE CLOSEST HOSPITAL, NOR THE ONE WE INTENDED TO TAKE HIM TO!
Before we discuss why, let me first tell
you that he is totally fine. He was a bit
dehydrated, which caused him to pass out. So why did they take him to a hospital farther away from our home, and…
Becoming the “Go -To” Person Sue Haviland and Brian Sacks
WHAT DOES ALL OF THIS HAVE TO DO WITH REVERSE MORTGAGES? The reason they took him to that particular hospital is because they are known for
having the best pediatric care around town. Seems strange that my 6-foot-1-inch kid
with a size-14 shoe is pediatric, but he is.
Now let‘s just take a step back and pull all
Last Sunday our 14-year-old son, Matt, wasn’t feeling well.
He had been complaining of a headache for a few days but we thought it was just the flu or a cold. Since he wasn’t feeling any
better we decided to call the doctor, who
14 | TRR
of this together.
The lesson here is that everyone in my area
knows that this hospital is the “go-to” place when children are involved, much like you need to be perceived as the “go-to” person when a senior needs a reverse mortgage.
Be a guest on a local TV show.
Be a guest on a local radio show that
deals with financial or senior-related issues.
Write a book. It’s not as hard as
you think. In fact we have helped
hundreds of originators create their own books and radio shows.
Be active in the community.
Get to know accountants, attorneys, financial planners, caregivers and
others in town. This is much more
than just networking; this is building a true professional network and will set you apart as a real expert.
Create your own blog and post to it (regularly!).
Have an informational website with relevant, up-to-date information.
It should be much more than just a landing page.
Contact your local media and ask them to do articles on
the new HECM Saver program – maybe a story on how you
There are numerous other ways to be seen as the obvious “go-to“
the appropriate product for a senior’s specific situation.
is that there are many options available (and they do not need to
you and your program. A good hook right now might be helped a client with it. Demonstrate that you recommend
Need assistance from the Advisor?
Congrats on Your CRMP… Now What? Alain Valles, CRMP
Offer to speak at local institutions and to various groups.
person. But the point we want you to take away from this article
be costly) to achieve this status. Pick a few and continue to perfect them and watch your reverse mortgage originations grow. g
Send your question to firstname.lastname@example.org and it may be addressed in the next issue. create awareness of and appreciation for the letters “CRMP.”
competence and associate it with CRMP.
This effort should begin while the ink is still drying on your CRMP business cards!
The “pull” part is the job of NRMLA. In
Start with the achievement itself. Make noise
by its members, NRMLA is educating the
releases, announcement cards to referral
order to make CRMP valued and desired
public about the importance of the CRMP
designation. Just as the American Institute
of Certified Public Accountants (AICPA) has made the “CPA” designation the standard by which all other tax and accounting
professionals are measured, so NRMLA is doing for CRMP.
Earning the designation of Certified Reverse Mortgage Professional (CRMP) from the National Reverse Mortgage Lenders Association (NRMLA) is a significant achievement.
By educating the public and aiming specific
— expertise, experience and ethics —
who have attained CRMP status. We want
mortgage services to your clients. But
mortgage to seek out a CRMP in the same
CRMP and understand what it means, the
planning and preparation.
Making CRMP meaningful will require a
at a local level. You need to do your part to
communications at trusted advisors (i.e. attorneys, accountants and financial
planners), NRMLA can give sanction to
CRMP as the sign of a preferred provider.
This will help to “pull” customer inquiries
about your accomplishment through press
sources and ads in local publications. Don’t let people guess what “CRMP” stands for; define the designation and its meaning clearly in order to build recognition.
Make sure you include an explanation of CRMP in all of your collateral materials,
on your website and in all presentations. Talk about CRMP at your business lead exchanges and Chamber of Commerce
breakfasts. Be proud of it and describe why it makes you a superior reverse mortgage provider.
It is proof that you have the “three E’s”
and create a public demand for loan officers
You can’t expend the time, energy and
necessary to provide exceptional reverse
seniors who are considering a reverse
then magically expect the world to recognize
unless prospective clients know about your
way a taxpayer insists on a CPA for tax
designation has very little value to you or
two-pronged approach, a “pull and push” to
The “push,” on the other hand, must come
money required to attain CRMP status and and understand what it means. Becoming certified is only the beginning of the job.
Now you must make the most of the title by
actively and aggressively promoting the fact that you are a Certified Reverse Mortgage Professional. g
develop an aura of professionalism and
TRR | 15
The Reverse Review December 2010 /January 2011
the Conversation The executive staff was hung over with cheer - Grand visions of back-end monies fluffed up their rear.
More products to the streets, with a creative touch - Maybe a real proprietary product am I asking too much?
When at the elevator door, there arose such a fuss - In came the processors, stumbling out from the bus.
Or a company that cares about the people it employs - Not just the few that will die with more toys.
Oh what a sight, one I didn’t expect - “Sit down,” they whispered, “I sent you a text.”
We need quicker counseling and appreciative appraisers - No more HUD letters and underwriters with Tasers.
I tore open my phone and put in my code Can’t trust a soul in this humble abode. It read, “We need a raise per file, and no more late nights - A new hourly schedule and the same L.O. rights.” I glanced behind at the stumbling crew WTF is this and why the new do? I thought at that moment, “This must be a joke - For the industry is down, and the printers are broke.”
The HECM Day After Christmas Dave Bancroft
‘Twas the day after Christmas, working as a lender - Not an
employee was stirring, not after this bender. The pipelines were hung, for the L.O.s not there - In hopes that they might find some time to care.
16 | TRR
They whistled and shouted, “This ain’t no game - We need better rep, more dedication and someone to blame.” I screamed, “O’ Come on Alex, Katie and Ray, - You know the new counseling rules are so gay. I can’t do much with the values of homes Or an underwriter with an eraser that looks like a gnome. So you’d best pump your brakes and get it together - Our reverse mortgage industry is under the weather.” “Captain,” they quipped, “What’s up with this funk? - Maybe we should tell rule makers, ‘Don’t touch my junk.’” Legislatures, you shouldn’t tinker or prod Let the markets run their course, don’t touch, just nod.
Less compliance, audits and expensive bonds - Cool should be the tempo, bring back the Fonz. More approved lenders and Ginnie guarantees - We want straight talk from all, especially pressured A.E.s. After a while, I slowed to a sigh - It’s been a long time coming for this diatribe. Cozy in my chair, I stared at the staff - Joy overcame me and I let out a laugh. We are all still working, and most doing good - Yes, there are problems, but this is our ’hood. Santa may have left, but opportunities abound - Right then through the door, came FedEx Ground. Arms stacked with packages, oh what a sight! - He said, “Sign here and here,” and disappeared to my right. I turned on my heel and couldn’t help but smirk - Exclaiming, “Stop your bitchin’ and get back to work. Be glad we can offer the HECM product of choice - Bringing happiness and peace to the senior voice.
Here’s to our futures, may they be steady and bright, Happy Christmas to all, and to all a good night.” g
The Essentials | iâ€™sen sh l | - your monthly source of in-depth information, industry updates, highly opinionated views and at-your-fingertips news. John Smaldone Michael Banner Lori Eshoo J a m e s E. V e a l e
It takes a lot to create an attention-grabbing, informative article and The Reverse Review is very fortunate to have worked hand in hand with industry leaders over the past couple of years. We are always searching for new writers and industry-related articles. If you are interested in contributing your views and have what it takes to intrigue our readers, we would love to hear from you! Email email@example.com to start the conversation.
TRR | 17
Will it Serve its Purpose? The industry
anxiously awaits the changes that come with the passage of the SAFE Act. John Smaldone
The SAFE Act (The Secure and Fair Enforcement for Mortgage Licensing Act of 2008) is one of the most confusing pieces of legislation put through
Congress in a long time. >>
After the most enormous expansion of values ever seen in the U.S. housing market, we also experienced the greatest economic and housing market crash since the Great Depression. For most of us, this was the beginning of the largest number of loan defaults and foreclosures we have ever seen. Credit tightened and financing became difficult to obtain, even for those with good credit and income. Home prices plummeted. The U.S. home foreclosure explosion was and continues to be a contributing factor in the global economic crisis. Congress, along with the American people, were taken off guard: Everyone was looking for answers. Why did this crisis occur, and how are we going to get this nightmare under control? Congress and the agencies turned their attention to the mortgage lending industry. This was an opportunity for the analysts to put the blame on mortgage loan originators and mortgage companies. The analysts were and are eager to blame the originators. They were also eager to make a point to emphasize that over the years loan originators had been >>
20 | TRR
lax or even deceptive
The analysts don’t mention
Securities were being
loans. This was not an
that were created after
vanilla product, then salt
entirely wrong analysis;
on the contrary, this was
and is a contributing factor to our problems, but not necessarily the primary cause.
We never seem to hear the
real story behind situations such as who is to blame
for the foreclosures, loan
defaults, the economic crash
and mortgage lending fraud. As an example: you do not
hear the analysts talk much about the Gramm–Leach–
Bliley Act President Clinton
signed in 1999. This was the act that eliminated much of the The Glass Steagall Act
all the wild loan programs the act was signed and
introduced, such as “No
Income, No Asset Loans,” “Option ARM Loans”
Loans” and even the “125% Loans With Stated Income Only.” I could go on and
on about the kind of loans
that were created between
1995 and 2007; this hayride went on for more than 12 years. Loan originators
were making more money
than ever and the subprime market was here to stay. I
could go all the way back to Reg-Z, but that story is for another day.
and opened the floodgates
The entire lending industry
did away with the most
competition was keen. In
to borrowing. This bill
normal and prudent loan underwriting guidelines.
We rarely hear the
federal government or the news media stating that the
real intentions were to stimulate a false, long-term growth by creating the
largest amount of
debt in the hands of
the American people. Housing loans, credit card
debt and overall borrowing soared to record levels. The
continuing accumulation of
debt lasted for over 12 years. The Gramm-Leach-Bliley Act signed by President
Clinton was the fuel that started the fire!
was uncontrollable. The order to compete in the
marketplace, lenders were creating new and wild
lending programs that Wall Street, Fannie Mae and
Freddie Mac all supported. Through its “Negotiated
Deals Desk,” Fannie Mae
bought into various lender
created programs and issued commitments on them.
pooled together with
and peppered with toxic loans. Wall Street firms
were getting these securities insured by the likes of AIG as long as they were able to be rated by the rating
agencies. The firms were getting triple – A ratings
on these securities, which were yielding better than a normal triple – A rated
security with 100% vanilla product in them. The
tainted securities were
triple – A rated because
of the insurance feature.
Why do you think so much of the TARP funds and
stimulus money went into AIG for bailout purposes and probably still is?
Claims started to skyrocket in the later years when
loans started to default.
The wave of defaults and
foreclosures are by no means over; they will continue. The federal government
could not allow AIG to go
under. Don’t forget China,
Russia, Germany and other
countries were buying these securities! The yields on
these securities were >>
The federal government says we must put most of the blame on the mortgage originator and the mortgage companies – they were the No. 1 culprits for all that has happened.
The truth is,
in qualifying buyers for
NEW YORK, NY -- SEPTEMBER 30, 2008: A Television Camera is Ready for Action Outside the New York Stock Exchange on September 30, 2008, the day after the record-breaking 777-point drop in the Dow.
the federal government, through its own deceptive methods of growing the economy, lured the predatory originators into the industry.
very attractive, enough for these countries to hop on the bandwagon and buy, buy, buy.
federal (SAFE Act) exam and meet any state requirements.
Fannie Mae and Freddie Mac were right in
What is the goal or purpose? The goal of
some of these securities from Wall Street for
government oversight and control over
the thick of things. In fact, they were buying their own portfolio! Do we actually believe all of this had no bearing on why we are where we are today?
this legislation was and is to establish more individual mortgage loan originators, with what government assumes will increase consumer protection.
The process is expensive and in many cases
the originator is paying the freight. All statelicensed and federally registered mortgage
loan originators must be registered with the Nationwide Mortgage Licensing System & Registry (NMLSR) maintained by the
Conference of State Bank Supervisors and the American Association of Residential Mortgage Regulators.
The federal government says we must
Government oversight did not work before
In my opinion, the new licensing
originator and the mortgage companies
Now, all of a sudden, it is supposed to
definitely rid the industry of many of the
put most of the blame on the mortgage
– they were the No. 1 culprits for all that has happened. The truth is, the federal
government, through its own deceptive
methods of growing the economy, lured
the predatory originators into the industry. In short, the bad guys were tempted with candy and they took it!
Something had to be done to control all the predatory lending and deceptive practices
of originators, right? Predatory lending and
what many originators were doing had to be stopped.
However, we must look at why the states
and the federal government along with its
agencies were not capable of enforcing what laws were on the books. Sound familiar?
due to incompetency within the agencies. work because the federal government
makes changes to their creative pieces of
legislation, which they never understood in the first place!
Residential traditional forward loans
Commercial real-estate lending
Requirements of the SAFE Act For all residential mortgage loan originators, except employees of federally charted institutions
Background checked and approved
Never have been convicted of a felony
The originator must be solvent
Never have had a revocation of a loan originator license
Complete the 20-hour pre-licensing educational course Correctly answer 75% of a 100-question written test
For each state the originator must post a surety bond, pay into a state fund or prove a minimum net worth
Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (the SAFE Mortgage Licensing Act).
Passage of the SAFE Act did not mean the act was implemented. The projected and announced date for implementation is
here: December 31, 2010. In order for an
originator to originate a loan and for it to be paid, he or she must have passed the
22 | TRR
of this new piece of legislation.
Now we come down to a new and confusing
responded and in July 2008 passed the
However, I see many problems arising out
residential mortgage industry.
System and Registry (NMLSR) for the
interference by big government. Congress
will also temporarily protect the consumer.
for a Nationwide Mortgage Licensing
piece of legislation created through more
predatory type originators, temporarily. It
Let’s look at the lending industry carved into four loan categories:
Primarily, the new law set forth objectives
Instead, our federal government felt that
the way to solve the problem was to create
requirements under the SAFE Act will most
The first two categories are the lending branches affected by the SAFE Act.
The same exam is given to those individuals that do traditional residential loans and to those doing reverse mortgages. You may say, so what? The reverse mortgage and
traditional residential lending industries
are like night and day to one another. The
exam under the SAFE Act is 95% comprised of and based on the traditional lending
industry or the forward lending industry, as we call it.
A mortgage loan originator employed by a
The education received that is in connection
any credit union or an owned and controlled
is very good; don’t get me wrong on this.
only register in all states. All other mortgage
in the business of originating loans, as well
licensed under the SAFE Act and licensed in
good points and benefits of the act.
federally insured depository institution, or
with the federal SAFE Act licensing program
subsidiary that is federally supervised, must
The education will benefit anyone that is
loan originators, without exception, must be
as benefiting the consumer. There are very
any state, where applicable.
the consumer any more than they were
than we have ever seen
I feel this will be the
The baby boomer population is soaring. The
We can’t afford to
will be enormous. It is obvious the federal
case in the future.
lose many of those that have been in
the reverse mortgage
Are WE losing
industry for years. Most of
these individuals are in the
business for the right reasons.
If the SAFE Act holds - up and it probably will - I feel we will need three types of licenses within the act, which I suggest to be the following: •
protected before the SAFE Act came into
A traditional/forward license that would
need and demand for reverse mortgages
government’s goal is to eliminate as much
of the small mortgage broker and even small community banks as possible. The demand for reverse mortgages should be strong;
however, I am afraid as time goes by we are going to see many lenders and mortgage brokers hanging it up.
We will always need people that have the passion for our seniors: individuals that
are educated in our product and those that understand what the phrase “fiduciary responsibility” means!
allow those not interested in originating reverse mortgages to originate traditional loans only. • However, we must
allow those that are not interested in
look at what can
originating traditional loans to originate
occur because of the complexity of the
required licensing act, when it pertains
to the reverse mortgage industry. We have
many originators that are seniors themselves and many of these originators only have
experience in the reverse mortgage industry. I have talked to many originators and a lot of them are not going to take the exam. In fact, some of them are going to leave the industry entirely.
Could we be cutting off our nose to spite
our face? Can it be that while initially we are eliminating the bad blood in our industry and establishing new and strict criteria to become a loan officer, we are also losing good people? Good people who have
served our senior population with passion, excellent service and sound counseling?
Could it be that we will see sharp-dressed, well-educated individuals who can pass exams with no problem but have more
A reverse mortgage license that would
reverse mortgages only. •
A combination license that would encumber both, traditional and reverse mortgages.
The SAFE Act is meant more for those who are not part of or affiliated with a federally
charted institution. Present day, the federal umbrella is the place to flock to if you are
an originator. In the not too distant future,
don’t think for a moment that the SAFE Act requirements will not be implemented for a loan originator working for a federally chartered institution.
This scenario may retain those that would
The industry is changing; many companies
industry and only this industry. The exam
are placing a lot less emphasis on building
should not be as intimidating as what is
goal has always been to establish trust
like to remain in the reverse mortgage
are going to the call center concept. We
will be on the product they know and
relationships, which is sad. Our first
before them today.
between the senior and the originator and
We still fall back on enforcement; those that
that. Will we and can we maintain this trust
relationship-building has accomplished
want to prey on our senior population will
factor with all the change coming our way?
will put us right back where we started.
I am not against change; I know it is needed
If HUD, the states and other regulatory
we go too far in changing our ways and our
are on the books, the SAFE Act just
with traditional methods and values, we
of a program our federal government
find a way to perpetrate such fraud, which
because of the times we are in. However, if
authorities do not enforce the laws that
approach to the industry by doing away
becomes another administrative nightmare
may see the beginning of the end of a great
created. We then wind up not protecting TRR | 23
The Reverse Review December 2010 /January 2011
2010...And We Thought 2009 Was Rough? Finding the good in the year behind us.
lmost exactly 12 months ago I sat down at my computer to write an editorial for The Reverse Review’s 2009 year-end double edition. I named the article “2009: The Year Success Became a Moving Target.” I had fun writing this piece and received a lot of positive response, which I always enjoy immensely. ¶ I started last year’s article with this statement: “If you are a reverse mortgage professional and you survived 2009, then you deserve congratulations. It was the most unusual year I have experienced in my 28-year career. “ >>
24 | TRR
Well, guess what? If you are a reverse mortgage professional and you survived 2010, then you deserve congratulations. It was the most unusual year I have experienced in my 29-year career!
Did you feel that? It’s reverse mortgage déjà vu… It’s not like there weren’t some incredibly positive moments in 2010. I think there
were two of them, to be exact. And they
may have actually saved this product and our industry from extinction, though few would admit it.
The first was in April. The decreasing of the origination fee, combined with the
elimination of the set-aside fees, was a gift from reverse mortgage heaven, in my opinion. No matter what anyone
says, the No. 1 obstacle that has kept the reverse mortgage from being embraced
as a mainstream product has always been the up front costs. This was an incredibly positive step for us as an industry and I
thank our industry leaders for stepping up to the plate.
The second came in October with the
introduction of the HECM Saver product. Whereas the reduction of fees made the reverse mortgage competitively priced
with other government-insured loans such as the standard FHA or VA, the HECM Saver – with its no upfront MIP – has
closing costs that rival a zero-point, fully documented, conventional loan. This is
incredible and exactly what we needed to
introduce this great product to the financial community.
But these two giant steps forward were severely hampered as home values
continued to plummet throughout most
of the nation. Here in Florida, where I do
the bulk of my business, nearly two-thirds of the inquiries coming into my company
never even made it to the application stage.
obstacle most had with this product: the upfront cost!
In fact, if I had to pick the most popular
With my customary and widely recognized
“My house is worth what?”
Orleans to attend the NRMLA trade show.
five words of 2010, they would have to be
The conversations with clients in 2010 were truly more disheartening than the ones
in 2009. It seemed in 2009 many people
were still in denial as to the value of their
home. They just didn’t want to accept the
bubble had indeed burst. I hated those 2009 conversations. Being the one to explain to a senior in need that the one option they
thought was available truly is not, is a very sad position to be in. And the position it left the senior in was even sadder.
But in 2010 the conversations became even more uncomfortable. In my opinion, most people did come to grips in 2010 with the fact that their home was just not worth what is used to be. What
“glass half-full” attitude, off I went to New
I only attended one breakout session in my three days in New Orleans. My goal for
making this trip was to meet with industry leaders and learn firsthand how 2010
affected their short- and long-term views of our industry, and how they saw 2011
unfolding in the midst of this seemingly never-ending recession.
Here are the results of some of those meetings: I finally had the pleasure to meet with
Marty Taylor, Owner/CEO of Stay in Home Mortgage, as well as his Sales Manager, Dennis Luschen; and his son, Brandon
Taylor, Vice President of Marketing. Marty
after accepting that their home had decreased
in value, they then had to hear that it actually
decreased much more
dramatically than they thought. This was a
double hit to these great seniors, and it really hurt.
2010 was another
rough year. But we survived, we still
have our loan limit of
$625,500 that so many
thought would be gone by now, and we have
two reverse mortgage
options to offer seniors (we literally doubled our product menu!).
Most importantly, we eliminated the No. 1
and I have become good LinkedIn friends via The
I feel made it worse was
It’s not like there weren’t some incredibly positive moments in 2010. I think there were two of them, to be exact. And they may have actually saved this product and our industry from extinction, though few would admit it.
Reverse Review group over the last two years, and it
was great to finally meet him. To me, these three
men embody everything good about the reverse
mortgage industry. They not only survived these crazy times but have
rebuilt their company and are going strong; they did it without straying from their “the good of the
senior comes first” attitude. I met with Mr. Bob Scott, National Director of
Genworth Financial Home Equity Access’ (GFHEA)
Affinity & Correspondent Relations. GFHEA is
Genworth Financial, Inc.’s
reverse mortgage business
in Rancho Cordova, CA. >> TRR | 25
Year in Review
I have known Bob for several years. He is
prosper. Seeing Mark and Dan achieve the
a true gentleman to spend time with.
is a great thing!
one of the pioneers of our industry and just
Hearing about Genworth Financial’s
Lastly, I also had the pleasure of meeting
was enlightening and very positive.
pioneers of the reverse mortgage industry
commitment to the reverse mortgage space
NMLS launches public mortgage licensing information resource
FHA appraisal independence rules take effect
HECM fixed with no servicing or origination fee introduced
First 4.99% Fixed HECM introduced
Lender paid MIP introduced, first no upfront fee HECM introduced
First CRMP designations awarded by NRMLA
Consumer Protection Act passed, creates Consumer Financial Protection Bureau
Federal Reverse releases final rules regarding mortgage originator compensation
SEP OCT NOV DEC
HECM Saver introduced by FHA
Fannie Mae exits reverse mortgage MBS business
Ginnie Mae announces lift of new issuer approvals Congress extends HECM lending limit at $625,500 through Sept, 2011
26 | TRR
success they have with their business model
Personally, I love it when a large and wellknown long-term care insurance company has that much of a commitment to our
industry. I have always professed that the relationship between long term care and
reverse mortgages is a ship our industry just keeps missing…
I also sat down with Mr. Alain Valles,
President of Direct Finance in Hanover,
Massachusetts. He has vast conventional mortgage experience and has embraced
the reverse mortgage arena and achieved success.
Speaking with professionals like Mark
Browning, principal of HomeChex, and Dan Osterhout of Community Senior Capital is always enlightening for me. They bring a
financial planning mindset to their reverse
mortgage business model (a business model that is near and dear to my heart). Their
vision of utilizing the proceeds of a reverse mortgage as part of an overall retirement
plan for seniors mirrors my own. The open discussions we had about the many ways
a reverse mortgage can be used to assist a
senior, other than the present “needs-based product of last resort,” were great.
This type of thinking tends to look at the
reverse mortgage in a much broader fashion than today’s reverse mortgage loan officer.
Again, in my opinion, bringing the reverse mortgage to the financial community – the
literally hundreds of thousands of certified
financial planners and independent financial advisors – and showing them this is not
just a product of last resort but can play a
valuable role in a senior’s retirement plan,
is the only way our industry will grow and
with the group from MetLife. They are true and it is always a learning experience to
spend time with them. Subjects discussed were the future of our industry itself, the potential the HECM Saver brings to the
table, and the potential of other segments of the financial industry becoming educated on the true benefits of this great product we offer. Having an icon like MetLife so
committed to the reverse industry tells me we are all on the right track.
So, what did I walk away from NRMLA with? The major players are in the market to stay.
They freely admit that the reverse mortgage is a work in progress. It’s going to have to keep morphing to survive this constantly
changing regulatory environment, as well
as the incredibly volatile financial markets, that dictate its future. To me this is a clear
message that we, the retail segment of the
industry, also have to be a constant work in progress and morph with the times as well. Now, with all due respect to the major
players, it’s much easier to accept change
and roll with the punches when you have a balance sheet that resembles that of a fairly nice-sized Third World nation.
For those of us that are very concerned
with the new net worth requirements and
upcoming changes in regulations regarding
our compensation in April 2011, it’s not such an easy thing.
In fact, I met many professionals in New
Orleans that came for one purpose only: to
find a new home. They are as committed
in this industry. This happens to be one of
being recognized as the incredible product it
any giant but simply do not have the
input. I’d like to say I’m going to miss 2010.
the needs-based traditional HECM and the
to this industry and serving seniors as
my priorities and I welcome any and all
wherewithal to do so. In fact, there are some
I’d like to say that, but I would be lying.
great opportunities out there right now for
Damn, I’m glad it’s over!
these entrepreneurs and I wish them the best of luck.
We enter 2011 with a certain feeling of
It’s quite possible that 2011 may be the
come and some of them are still unknown.
apprehension. Many changes are still to
year of the “roll up.” I feel there is a great
But as an industry we are still standing
opportunity for retail industry leaders
proud. Thanks to the constant efforts of
to consider joining forces. A handful
NRMLA and all the players, from the giants
of independents strategically located
right down to the small independents,
throughout the country could be a real force
is. We have two great products to offer now: HECM Saver.
So we keep moving forward. We keep the needs of our seniors our No. 1 priority
and we help as many of them as we can.
Nothing silences critics quicker than success. I wish you and yours a very happy, healthy and prosperous 2011. g
slowly but surely, the reverse mortgage is
New year’s resolution: a commitment that an individual makes to a project or the reforming of a habit, often a lifestyle change that is generally interpreted as advantageous. ¶ The Reverse Review asked people in the industry what their new year’s resolution was for 2011 and we received an overwhelming response. Here are some of our favorites…
Sarah Hulbert Seattle Mortgage Dust off my Gratitude Journal and take time every day to record at least one thing for which I am grateful, be it in my personal or professional life. I think it is so important for all of us to step back and reflect on how blessed we are in our lives!
John LaRose Celink Celink resolves to continue fostering an attitude of tremendous gratitude for our industry, our clients and their borrowers. I personally resolve to always do the right thing, not take myself too seriously, and spend more time with my grandchildren.
Dave Bancroft Give more, love more, hug more, kill less, maim less, wound less, pray more, spend less, drink no more and no less!
Atare Agbamu Author, Think Reverse In 2011, I resolve to give thanks more, to laugh more, to sing more, and to dance more.
Lori Eshoo National Tax Search To implement a full-service tax and insurance program for homeowners and lenders.
Michael Detwiller, CEO, Mortgage Cadence, LLC To personally influence two in-need borrowers to consider a reverse mortgage as part of their overall financial plan.
Brett Varner The Reverse Review To align with others that share an entrepreneurial spirit focused on growth and development through innovation, education and teamwork.
Trevor Gauthier Mortgage Cadence, LLC To become the single most sought-after company for origination technology and document solutions in the reverse mortgage space.
Karen Keating Tradition Title Tradition Title’s goal for the year 2011 is to assist our clients to increase their overall reverse mortgage volume by 25%. My personal goal for 2011 is to be in the best shape physically.
Jim Veale S1L As to the RM industry, my resolution is to begin building a relevant educational bridge into the professional gatekeeper community.
John Smaldone Hanover Financial I will help and befriend 10 more of our troops overseas in 2011 than I did in 2010.
TRR | 27
The Reverse Review December 2010 /January 2011
e c n
a r u
s n i
social security Lori Eshoo
Unwinding the Property Tax and Insurance Obligation Spotlighting the concerns that lenders and brokers are facing.
ccording to USA Today, over 3 million of the 79 million baby boomers will reach the retirement age of 65 in 2011. Numerous organizations will be perceptibly affected by this substantial occurrence. If each industry sector hasnâ€™t already made the necessary changes to their business structure in anticipation of the tidal wave of retirees, they may want to consider doing so as quickly as possible in order to handle this growing market in a successful manner. If lenders, brokers and other businesses donâ€™t take the appropriate steps, they may lose out in billions of dollars in revenue by not catering to this market for the next 20 years. >>
28 | TRR
Decades ago, the question of how senior
important, but it may actually be the most
Stanley also believes that counseling can
future once they retire was a hot topic
just for seniors but for the lenders and
on the options that are available, but an
citizens would financially secure their
for many organizations. In retrospect, a government solution to this issue was
critical action in the overall process, not third-party vendors as well.
The HECM counseling agencies may
Mortgage (HECM), which is managed
options on lender and third-party services.
through the U.S. Department of Housing
and Urban Development (HUD). As long
as each party adhered to the requirements, the HECM option seemed to be the ideal
financial solution because it benefited both the borrower and lender.
So why is the HECM, which seemed to be
essentially act as the gatekeeper, providing The reverse mortgage counselor’s access and knowledge of various available
reason may be, the industry is determined to find a solution that makes sense for all
relevant parties and ultimately, the senior community.
Here, we will dig a little deeper and
place the spotlight on the most prevalent concerns that lenders and brokers
are currently facing: property taxes
and homeowner’s insurance defaults.
Furthermore, we will discuss how these two factors relate to the overall HECM portrait and the pertinent roles that
lenders, brokers and third-party vendors play.
Counseling with the Right Organization As industry associates may already know,
the first step in helping senior citizens rests on the shoulders of the HECM counselors.
These agencies are responsible for advising the borrowers of eligibility requirements,
financial implications and any alternative solutions to obtaining a HECM. This
initial step may be perceived as the least
paycheck before we could spend it?”
Although seniors who plan on retiring
counseling agencies across the U.S.
determine if their current expenses will
International Senior Vice President of shares his insight from a counselor’s
perspective: “One thing we have learned from all our
will receive Social Security benefits, they
may have to re-evaluate their resources to
Education and Community Relations,
played a considerable role. Whatever the
deduction was not taken directly out of our
(RMCA) is the entity that trains the many
Mortgage Counseling Association
Perhaps the deteriorating real estate market industry during the last several years have
would really save for retirement if our 401k
the consumer and lender. The Reverse
Chuck Stanley, Money Management
and the credit issues that plagued the
also added, “Honestly, how many of us
From the Lending Institution’s Perspective
programs will continue to benefit both
dormant for a while, now seeing a burst of activity within the lending industry?
easier solution in the marketplace is needed for reverse mortgage borrowers. Stanley
to create the reverse mortgage option,
specifically the Home Equity Conversion
play an increased role in educating seniors
be covered by the fixed income. With the
increasing concern that the Social Security system may potentially collapse, finding alternative options for income may >>
in educating consumers is that it is
very hard for
save for tangible wants or needs. It is even
harder to save for something they see no immediate
material reward for, such as insurance
and taxes. It
is, of course,
essential to save for insurance
and taxes, but it is easy to
Are you concerned about tax and insurance defaults? National Tax Search, a certified Women’s Business Enterprise (WBE), provides web-based services via our award-winning TaxQ system. Take advantage of the following:
Tax Certiﬁcation (snapshot of tax status) Delinquent/Sold Tax Monitoring Property Tax Payment Processing Escrow Analysis and Tax Projections Property Tax Credits and Exemptions Insurance and Flood Determinations Property Inspections Death Certiﬁcation Valuation Analysis and Tax Appeal Services
needs or wants take priority.”
303 E. Wacker Drive, Suite 1040 | Chicago, IL 60601 Tel: 888-627-5494 | Fax: 888-294-8151 www.nationaltaxsearch.com | firstname.lastname@example.org
TRR | 29
become a vital necessity within the next
lender’s risk on their investment, seniors
According to studies conducted by the
a more limited loan option with lesser funds
two decades for the senior community.
who are at a higher risk of default are given
trustees who monitor the government’s
elderly programs, Social Security may run
out of funds as early as 2037. Although this date surpasses the end of the baby boomer retirement era, changes in government
policies and regulations may potentially
age of 70 are most likely to default on their reverse mortgage loans, so the HECM
counseling agency and the lender should
Moreover, with the economy just recently
The HECM has made a big impact on
corporations eliminating pension plans, the
during retirement because in many cases,
emerging from recession and with many
need to secure finances at retirement is even more crucial to balance any obstacles that seniors may face during their retirement
period. With that being said, the lending
seniors in managing their means of living the funds have been used to help pay for the borrower’s remaining mortgage balance, property taxes, homeowner’s insurance, home maintenance and other debts that
industry becomes the main focal point in
the next step as seniors are ready to move forward with the HECM process. The
flexibility of the lending institution and their loan options will determine if seniors will
experience a retirement process that is either manageable or unbearable.
may have accumulated. Without the
HECM, many seniors may even be forced to
postpone their retirement in order to sustain their current living arrangement, keep up
with the costs of living and prepare for the unexpected expenses that may transpire. Although lenders are part of the big
Lenders and brokers obviously want to
make the whole experience for the seniors as painless as possible without losing the
profitability of their investments. Lending institutions and other agencies have been
equation in getting seniors to a point of
financial stability, third-party vendors may
also play an integral role in this multifaceted picture.
service offering that is more attuned to the
Benefits of the Third-Party Vendor Relationship
risk group and the high-risk
Before the borrower decides to accept a
fully understand that certain liabilities still
working together to provide a modified different types of borrowers: the lowcrowd. In order to
670 , 1 2
9 14, NORTHEAST
remain their obligation, such as paying
property taxes, homeowner’s insurance and
ongoing home repairs. Unlike the traditional
HECM loan, they must also be aware and
26 0,1 6 8,0
Source: U.S. Census Bureau, Population Estimates as of July 1, 2006.
studies show that borrowers under the
product that optimizes everyone’s financial
mortgage loan that gives borrowers an
option to escrow for taxes and insurance premiums, a reverse mortgage does not carry a regulatory requirement for an
number of years until depleted
available from the HECM loan. Industry
focus more effort on education and offer a
end Social Security benefits earlier than
Population by Region
Yr depleted 30
Yr change in Projected depletion
Source: Office of the Chief Actuary, Social Security Administration.
Borrowers will need to either put away enough funds each year to cover these
expenses or find a way to establish escrow services to reduce the risk of defaulting
on the loan. Ensuring that property taxes and insurance premiums are paid in a
timely manner is essential because once the borrower neglects to make these payments; the lender will also discontinue paying
the borrower the funds from the HECM
loan. Clearly, both parties will lose as the
borrower will be in deeper waters without
the funds, and lenders may not receive the
return on investment they were anticipating. Lenders would, of course, have more control over these liabilities if an escrow account was established.
One solution is to develop a partnership
with a third-party vendor, who specializes
in the administration of property taxes and has the capability to establish an escrow
account to collect the appropriate funds. In this unpredictable market, using a third-
party vendor provides more flexibility and informs all parties of the detailed property tax data, so payments can be made timely
HECM are following protocol
Lenders are aware that
protection needed to retain the
managing property taxes can be a burdensome undertaking and
and will also provide lenders the value of their investment.
unless they are familiar with the
Today, lenders can access critical
each taxing jurisdiction (20,000-
third-party vendor with 24-hour
ever-changing requirements of
plus in the U.S.), property taxes can become delinquent and
accrue penalties. In a worstcase scenario, the property
owner can lose their investment
through a tax sale or foreclosure. Additionally, due to the current
economy, taxing jurisdictions are experiencing budget cuts and a
reduction in staff, resulting in a reduced threshold in assisting borrowers with reporting and
payment requirements. As taxing jurisdictions continue to make changes to their procedures
and requirements and execute late releases, the importance
of working with an expert is accentuated.
Vendors can assist lenders in their efforts to mitigate loss and reduce fraudulent activities by offering other value-added services,
such as property inspections,
insurance monitoring and death certificate searches. Vendors can also provide other services such
as an annual abatement or senior credit review, and tax appeal
services that may directly assist
seniors in reducing the assessed
value of their home and property taxes. Vendors can work with all relevant parties, from the lender to the FHA-approved appraiser, to meet the requirements for a reverse mortgage and lessen
any apprehension the borrower may be feeling. These services
will ensure that borrowers with
The RESPA Challenge
property tax information via a
web-based technology. Property tax vendors can also make the
payment process much simpler by ensuring that payments are properly posted at the taxing
jurisdiction for their escrowed
borrowers and also identifying tax liabilities that need to be
properly monitored when their
non-escrowed borrowers fail to
make their property tax payments. Lenders should also keep vendors in mind who can offer services in an automated method to reduce
errors that may occur with manual processes.
Despite the many barriers, the HECM may become the only option for many seniors. On
the other hand, if borrowers are able to handle their financial
obligations in the most opportune
fashion, the benefits will outweigh
lending institutions and third-
Stricter RESPA rules, lower principal limits, a more complex FM1009 and other changes pose a serious challenge to our industry. Lenders will take on additional responsibilities and need to be meticulous while working with brokers. Brokers will lose all or most of the YSP and any mistake made in the GFE could cut into their origination fee as well.
support of government agencies,
But there is also good news around the corner...
the drawbacks in the long run
and provide the peace of mind
they are seeking. In the end, the borrower must absorb all of the information they have learned in making the best decision
concerning their finances to secure their future after retirement.
However, the counseling agencies, party vendors, along with the
should take the responsibility to properly educate and provide
the tools and resources to assist
seniors in achieving their goals. g
3310 Pollock Place â€˘ Raleigh, NC 27607 www.reversevision.com (919) 834 0070 â€˘ email@example.com
TRR | 31
The Reverse Review December 2010 /January 2011
James E. Veale
Taxation on Foreclosure Part III Determining the amount of debt forgiven.
hen it came to reverse mortgages four years ago, the discussion of foreclosures was received as if it were a fruitless mental exercise into the ridiculous and absurd. The value of homes was accelerating, county lending limits were rising, and the potential for the growth of the reverse mortgage industry seemed endless. High accelerated growth in home values covered up many underlying problems, but then came the downturn in the housing industry. How things have changed.Âś Many seniors reasonably expect their reverse mortgages to terminate into foreclosure or one of several similar transactions. >>
32 | TRR
Most have been told that reverse
is greater than the proceeds
free,” which may prove to be
of the property securing the
mortgage proceeds are “tax-
true for many but not for all. Further clouding the HECM
foreclosure future are technical defaults. These were once
believed to be about 1% of all
outstanding HECMs, but now
even the HUD OIG is telling us that number could be closer to 4%, if not 5%. How HUD will
attack this problem still awaits an answer.
In Part III, we will begin
received from the disposition reverse mortgage; or (2) the balance due is greater than
the fair market value of such
property at the time when the
property is transferred to “the lender.” Since there is little
expectation that discharge of
indebtedness will occur with
reverse mortgages outside of
this series focuses primarily on those transactions.
amount of debt forgiven for
Summary of Parts I and II
probe its components.
By federal law [15 USC
looking at how to measure the income tax purposes and will
1602(bb)], all reverse mortgages
The purpose of this series of
HUD specifically declares
income tax information
only in Mortgagee Letter 2008-
articles is to provide general about the discharge (i.e.,
cancellation and forgiveness) of indebtedness related to
reverse mortgages. It is assumed throughout the series that the property securing the
reverse mortgage has only
been used by the borrower as
HECMs to be nonrecourse not
38 but also in Paragraph 1 3C of HUD Handbook 4235.1 REV-1. Despite industry assertions to
the contrary, it is the note that makes a HECM nonrecourse for a borrower, not FHA “insurance.”
a principal residence (unless
Whenever amounts due are
else. Please see the section
in a taxable disposition such
otherwise noted) and nothing titled “Disclaimer” for more information.
For the purposes of this series,
“foreclosure” includes not only actual foreclosure but also its
subset of transactions including short sale, trustee sale, deed
in lieu of foreclosure, and any
other disposition of the property securing a reverse mortgage where (1) the balance due
The RESPA Opportunity
ReverseVision's international team of software engineers, attorneys and mortgage specialists turn these challenges into opportunities. They build the tools that give their customers a competitive advantage. This is why over 6000 reverse mortgage specialists in over 600 companies rely on ReverseVision every day.
forgiven on a nonrecourse debt as foreclosure, specific rules
under Internal Revenue Code
(IRC) Regulation (Reg.) Section (§) 1.1001-2 apply. Although
there are no income tax laws, regulations, rulings, or
Can you afford not to use ReverseVision?
court decisions specifically related to HECMs, one of
the leading cases on the tax
treatment of nonrecourse debt involves an >>
3310 Pollock Place • Raleigh, NC 27607 www.reversevision.com (919) 834 0070 • firstname.lastname@example.org
TRR | 33
FHA-insured loan [Allan et al versus
It is important that servicers complete
Mr. Yedinak goes on to say: “Essentially,
856 F.2d 1169 (8th Cir. 1988)]. Despite FHA
Revenue Service (IRS) income tax form,
a new appraisal after the loan has been
Commissioner, 86 T.C. 655 (1986) affirmed taking over the loan through default, the
Tax Court (as affirmed by the Eighth Circuit Court of Appeals) treated the transaction as it would any other nonrecourse debt.
The amount of debt forgiven will generally either increase gain (or decrease loss) since
and file the appropriate federal Internal Form 1099-C, when any part of a reverse
mortgage is forgiven whether or not the loss is reimbursed by FHA. Such information is
needed by borrowers and their tax advisers to prepare income tax returns reflecting the amount forgiven.
the amount forgiven must be treated as
the feature allows borrowers to order
originated and if it indicates the value of the property is less than 80% of the outstanding balance of the note, the
mortgage amount due will cease to accrue
interest. However, Generation has the right to order a subsequent appraisal[s] at its discretion and if the appraisal finds the
additional proceeds received in the taxable disposition. To the extent that accrued
interest is forgiven and increases the taxable
proceeds, it is treated as paid and may result in favorable tax benefits.
When forgiveness simply decreases a loss
on the sale of a principal residence, it has no
It is clear that all loan proceeds that are forgiven must be treated as additional taxable proceeds in the determination of gain or loss – but are accrued interest, fees, MIP, and other costs that may be forgiven taxable in the same way?
practical tax detriment since a loss from the taxable disposition of a principal residence is a personal loss and cannot offset any gains or ordinary income.
Even when the forgiveness increases gain, such gain may be:
Entirely or partially
excluded under the limited exclusion rules pertaining to the sale of a principal residence.
Determining the Amount Forgiven and Its Components
value of the property is more than 90% of
It is clear that all loan proceeds that are
will start to accrue again.”
forgiven must be treated as additional
It is clear from the RMD article that
MIP, and other costs that may be forgiven
interest that is forgiven can expose the
gain or loss – but are accrued interest, fees, taxable in the same way?
Mr. Jeffrey M. Lewis, gave us a hint of
Partially or fully offset by: a) capital losses or B) o therwise available
itemized and exemption deductions in excess of
other gains and ordinary income.
how much he believes is taxable when proprietary reverse mortgage debt is
forgiven in company materials discussing the Gen Plus Estate Guard feature, which it distributed to its correspondents. Mr.
Generation Mortgage believes that accrued borrower (or heirs) to significant income
tax liabilities. There is little doubt that this conclusion is correct since the relevant regulation and the courts calculate the
amount of nonrecourse debt forgiven as the difference between the amount due on the
debt and the value of the property and cash received by the lender.
John Yedinak cited a portion of those
Generation Mortgage should be commended
(RMD) article titled “The Return of Jumbo
likelihood Generation Mortgage would
materials in a Reverse Mortgage Daily
Reverse Mortgages: A Closer Look,” dated June 17, 2010, stating: “The benefit is that
despite the nonrecourse nature of the loan,
borrowers and heirs are potentially exposed to significant tax liability if the future home value is not sufficient to cover the accrued loan balance.”
34 | TRR
time of the subsequent appraisal, interest
taxable proceeds in the determination of
Generation Mortgage, headed up by
the outstanding balance of the note at the
for providing Estate Guard. There is little
ever be materially harmed by the exercise of Estate Guard since it is highly unlikely that the value of a home would grow to cover the interest not accrued under the Estate
Guard provision, plus all additional accrued interest even if home value returns. On the other hand, borrowers who exercise Estate
borrower has in the home for income tax
...borrowers who exercise Estate Guard can potentially reduce the impact of income taxes from the cancellation of debt.
Since the proprietary reverse mortgage is nonrecourse, lenders/investors will receive the same amount paid back to
them whether there is a provision like Estate Guard or not. But by electing
Estate Guard, the borrower is forgiven less accrued interest. This feature may potentially shelter the borrower (the
estate or heirs as well) from at least some Guard can potentially reduce the impact of
exposure to income tax liability if any of
income taxes from the cancellation of debt.
the debt is ever forgiven.
For example, a home
Estate Guard could be a big help, especially
interest because of home mortgage
balance due on the
situations, electing Estate Guard could
$2,200,000. In two
interest. This would be especially true if
has grown to $1,900,000 but the balance
the increased gain or lower loss was less
surrenders the deed in lieu of foreclosure
would be lowered through the deduction
netting $1,767,000 ($1,900,000 less selling
the rules regarding the deductibility of
$787,900. The borrower would be forgiven
hand, if the borrower invokes Estate Guard
It is very doubtful if a feature like Estate
until it terminates, and the loss suffered
reason is simple: If the lender/investor
($2,200,000 minus $1,767,000) with the
HUD is not required to reimburse it.
This could save the borrower potential
It is important to realize that not only
minus $433,000) of increased gain.
accrued interest and any other costs,
(It is important for readers to remember
exclusion and offsets like capital losses
determined from the information provided
mortgage debt forgiven, most HECM
determined by subtracting the adjusted
income tax liability from the forgiveness of
sales price. The example above provides
may not be true for their estate or heirs. g
if the borrower cannot deduct the related
$1,500,000 but the
interest limitations. However, in limited
reverse mortgage is
restrict the deduction of otherwise accrued
years at termination, the value of the home
the increased income tax liability from
due is now $2,554,900. If the borrower
than the amount the income tax liabilities
and the bank sells the home for $1,900,000,
of the additional accrued interest; however,
expenses of 7%), then its loss would be
interest are beyond the scope of this series
$787,900 of the debt incurred. On the other
now, the loan would be frozen at $2,200,000
Guard will ever be offered on HECMs. The
by the bank would be artificially $433,000
does not charge interest, under current law
amount of the loan forgiven also $433,000. income tax liabilities on $354,900 ($787,900
The IRS requires that readers are
informed that the information contained in this series of articles cannot be relied upon or used to reduce any income tax penalties (or interest). Readers
are encouraged to consult competent
and knowledgeable tax professionals
experienced in such matters to determine how the information applies in specific situations.
The tax rules described are limited to
federal tax rules; state and local tax rules may vary. The information is time-
sensitive since laws and application of laws can change over time.
The series only addresses simple
situations. Far more complicated
situations may exist including but not limited to: •
nonrecourse but also recourse debt is forgiven.
Applicable property was fully or partially used in a trade
or business of the taxpayer
(including rental activities) at the time of foreclosure or in some prior period.
It also does not address other
complications such as use of funds for purposes of: •
Allocation of gain between passive and non-passive
trades or businesses, portfolio, and personal activities.
can proceeds become taxable, but so can including MIP. With the limited home gain
Situations where not only
Allocation of interest between such activities and home
mortgage interest for tax-
that the income tax gain or loss cannot be
available to borrowers who have reverse
in the example. Income tax gain or loss is
borrowers will not incur any additional
This article focuses solely on reverse
basis of the property from its adjusted
debt related to a HECM, although the same
Housing Administration (FHA), known
no information on the adjusted basis the
mortgages insured by the Federal
as HECMs (Home Equity Conversion Mortgages), and proprietary reverse
mortgages provided by major lenders.
TRR | 35
the Resources Information at your fingertips. A listing of advertisers and contributors featured in this issue.
iReverse Home Loans
Reverse Market Insight
Attorney Trust Review
LoanWell America, Inc.
Reverse Mortgage Success
Direct Finance Corp
National Tax Search, LLC nationaltaxsearch.com
Hanover Financial Services email@example.com 865.980.3583
Reverse Fortunes reversefortunes.com 800.805.9328
RMS Asset Management Solutions reotosell.com 281.404.7969
Security 1 Lending s1l.com 619.794.0797
3,550,000 36 | TRR
The number of people who will be turning 62 in 2011.
The Reverse Review December 2010 /January 2011
Word the HECM Saver fit? Is it just another loan variation, or is it much more?
Swiss Army Knife The full benefit of the HECM Saver quite frankly escaped me when the product’s early details began to emerge. We
understood there would be a reduced upfront FHA insurance premium in
exchange for less money (thus posing less risk to FHA). However, prior to its full
disclosure, we didn’t know just how farreaching the HECM Saver would be.
In essence, the HECM Saver is the Swiss Army knife for our industry, accomplishing several key objectives simultaneously.
HECM Saver: Swiss Army Knife for our Industry
It’s easy for lending professionals to look at a new loan product or design as just another flavor we offer. But in the
reverse mortgage community, where does
the veil of reduced upfront costs, the
HECM Saver holds great potential to be an integral part of a retirement plan.
Third, and generally
unknown, the HECM Saver has spared the reverse mortgage industry from
principal limit factor cuts, protected the
overall HECM program, and dramatically reduced the subsidy request for this fiscal year.
Low-Hanging Fruit The first people to approach with the
HECM Saver are those who had rejected the traditional reverse mortgage due to
high upfront costs. Even prospects who liked the idea of no origination fee may
not have wanted a fixed rate loan, or still
First, the Saver is chipping
disliked the high upfront insurance costs.
and media’s negative
fairness, the Saver is more evenhanded in
The fixed rate and high
leaves their line of credit mostly untouched
that fueled competitive
the spendthrift who burns through funds?
what happens when the
where the borrower “pays as they go” or
away at the public
If you look at it from the perspective of
perception of high costs.
its approach. Why should a borrower who
profitability of these loans
pay the same up front FHA insurance as
pricing began to help, but
In reality, it’s a “risk-based” approach
markets inevitably change? The HECM
as the loan balance grows, thus increasing
reduced upfront costs. One HUD official
with the substantially lower LTV (loan to
Saver is the long-lasting solution with
the “crossover” risk to FHA. However,
described the pricing as “pay as you go.”
value) the Saver offers, one can quickly see the risk of these loans going upside
Second, we now have a
down is negligible. Thus the ongoing FHA
with which we can
losses anticipated this fiscal year for the
community as a lower-
uniquely priced product
insurance charged on Savers will offset the
approach the financial
Standard HECMs, where the risk is
cost alternative. Behind
TRR | 37
application, problem or case design where
Another market to approach are those who have had their existing home equity lines
of credit reduced or flat-out revoked due to
falling home values. Partnering with smaller local banks and credit unions can help find these homeowners who have lost access
or cannot qualify for a traditional HELOC.
Then, of course, there are those parents who cringe at the thought of using up all their children’s inheritance. When managed,
the Saver can give them the cash they may
need while preserving the estate for the next
While new isn’t always better, the HECM Saver is an improvement, an opportunity to reach the retiring boomer generation and a boost for the overall health of our industry.
them with the same generic messages: “I’m
If we were to honestly evaluate our
(please: not income), “financial tool” and
community and professionals, the word
a trustworthy loan officer,” tax-free cash liquidity.
“lacking” comes to mind. Seniors who are
While these statements are generally
advisor typically fall outside the “needs-
imagination of the financial advisor. In
actively engaged with a CPA or financial
based” client we have attracted in the past, yet for the most part, we have approached
38 | TRR
sales force must educate itself on how to
approach financial professionals. A good place to begin is by identifying the most common challenges their clients face. Is
“debt management” a consideration besides asset management alone?
While new isn’t always better, the HECM Saver is an improvement, an opportunity to reach the retiring boomer generation
and a boost for the overall health of our
industry’s success in reaching the financial
it can provide a solution. Our current
true, this approach fails to capture the
reality a reverse mortgage is merely a loan (not a financial tool) until it has a specific
industry. Adoption of the Saver is a win-win as we better meet the unique needs of the
borrower and bolster the Standard HECM, insuring its health. A Swiss Army knife, indeed. g
keting Lead Improve Grow Debate Discuss RESPA TILA HECM Save Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Lette FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RE SPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compli ance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Dis cuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Mar keting Lead Improve Grow Debate Discuss RESPA TILA HECM Save Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Lette FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RE SPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compli ance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD Compliance Marketing Lead Improve Grow Debate Dis cuss RESPA Advertise TILA HECM Saver Fixed LIBOR Mortgagee Letter FHA HUD with The Reverse Review | firstname.lastname@example.org Compliance Marketing Lead Improve Grow Debate Discuss RESPA TILA
A NEW YEAR
A NEW LOOK
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