Thursday, June 23, 2016

FYI: CFPB Report Emphasizes Servicer Loss Mitigation Errors, Technology Systems and Training Deficiencies

The federal Consumer Financial Protection Bureau (CFPB) recently issued its "Supervisory Highlights - Mortgage Servicing - Special Edition" (Issue 11), addressing examination issues reportedly found as to loss mitigation acknowledgement notices, loss mitigation offers and related communications, loan modification denial notices, servicer policies and procedures, and servicing transfers. 

 

Of note, the Supervisory Highlights also addresses the CFPB's approach to mortgage servicing examinations, including as to recent changes to the mortgage servicing chapter of the CFPB Supervision and Examination Manual.

 

A copy of report is available at:

 

http://www.consumerfinance.gov/documents/509/Mortgage_Servicing_Supervisory_Highlights_11_Final_web_.pdf

 

The CFPB summarized its findings as follows:

 

Outdated and deficient servicing technology continues to pose considerable risk to consumers in the wider servicing market. These shortcomings are compounded by lack of proper training, testing, and auditing of technology-driven processes, particularly to handle more individualized situations related to delinquencies and loss mitigation processes. None of these problems is insurmountable, however, with the proper focus on making necessary improvements, especially in the information technology systems necessary for effective implementation. Supervisory examinations do show that some servicers have significantly improved their compliance positions, and this edition concludes by sharing how these servicers have strengthened their compliance.

 

Loss Mitigation Acknowledgment Notices

 

Among other things, according to the CFPB, examiners found the following errors as to loss mitigation acknowledgment notices:

 

- Stating that documents were due by a deadline or that foreclosures would not occur before a deadline passed for submitting missing documents, but then denying modifications or foreclosing before the submission deadline.  Of note, the CFPB "determined the representations to be deceptive, independent of whether or not the servicing rules permitted the servicer(s) to foreclose on the specific borrower(s) at that time."

 

- Sending acknowledgment notices that did not "state the additional documents and information for borrowers to submit to complete the application, such as income and tax forms that the servicer's internal

records showed were necessary at that time," but instead requesting the documents by separate letter "several weeks after the acknowledgment notice."

 

- Requesting irrelevant or inapplicable documents, or documents that the borrower already submitted

 

- Not including "any reasonable date by which borrowers must return additional documents and information."

 

- Failing to "include a statement that borrowers should consider contacting servicers of any other mortgage loans secured by the same property to discuss available loss mitigation options."

 

 

Loss Mitigation Offers and Agreements

 

Among other things, according to the CFPB, examiners found the following errors as to loss mitigation offers and agreements:

 

- Stating that the servicer would defer outstanding fees, charges, and advances to the maturity date of the loan, but then assessing many of these charges when the borrowers signed and returned the permanent modification agreements.

 

- Using proprietary modification offers that "made it impossible for a borrower to understand the true nature of how and when these charges would be assessed."

 

- Using response deadlines that had already passed

 

- Generating letters in a timely fashion, but then delaying their delivery

 

- Sending offer letters with unapproved terms

 

- Stating in "trial period plans that borrowers would receive a permanent modification after making three trial payments" without conditioning the offer on the results of a title search, and then denying a "permanent modification based on the results of a title search."

 

- Treating "self-employed gross income as net income when evaluating loss mitigation applications."

 

- Not timely converting trial modifications into permanent modifications, and then capitalizing the additional interest due under the pre-modification rate into the principal balance owed under the permanent modification, and continuing to report the borrowers as delinquent during the period of the delay

 

- Stating that "deferred interest would be repayable at the end of the loan term when, in fact, the servicer collected the deferred interest from consumer immediately after the deferment ended."

 

- Including waivers of consumer rights in loss mitigation agreements. 

 

 

Policies and Procedures

 

Among other things, according to the CFPB, examiners found the following errors as to servicer policies and procedures:

 

- Not "promptly identifying and facilitating communication with the successor in interest of the deceased borrower with respect to the property secured by the deceased borrower's mortgage loan," but instead requiring "probate for borrowers to establish themselves as successors in states where probate was not required."

 

- "[S]oliciting loss mitigation applications when internal records showed that the borrowers were not eligible for any loss mitigation option."

 

- Not identifying and processing materials submitted by borrowers to complete a loss mitigation application, including "date-stamping, cataloging and distributing loss mitigation material to appropriate

Departments."

 

- Evaluating loss mitigation "applications only for the loss mitigation options preselected by servicer personnel and not for all options available to the borrower."

 

- Not properly sharing accurate and current information regarding the status of loss mitigation, such as with foreclosure counsel.

 

- Not identifying "necessary documents, including loss mitigation agreements and mortgage notes not transmitted by the transferor" servicer.

 

 

Servicing Transfers

 

Among other things, according to the CFPB, examiners found the following errors as to servicing transfers:

 

- Not honoring in-place trial modifications following transfers of servicing

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Wednesday, June 22, 2016

FYI: Maryland Fed Ct Allows Bank to Recover Allegedly Unauthorized Advances on Frozen HELOC

Reversing a Bankruptcy Court order in favor of the debtor, the U.S. District Court for the District of Maryland recently held that a bank that had allowed amounts to be withdrawn from a home equity credit line after the HELOC had been frozen could still recover those amounts from the debtor.

 

A copy of the opinion is available at:  Link to Opinion

 

During 2006,  the bankruptcy debtor and his former wife underwent divorce proceedings, and the debtor instructed the creditor bank holding his home equity line of credit (HELOC) to freeze the HELOC.  On June 22, 2006, the creditor bank wrote to the debtor's former wife a letter serving as notification of the HELOC freeze.

 

Subsequently, the former wife withdrew funds from the HELOC via two checks. On October 2, 2006, the creditor bank sent a letter to the debtor's former wife stating the withdrawals were unauthorized and that she should return the funds.

 

During bankruptcy proceedings, the debtor objected to a claim filed by the bank for the withdrawal amount. The Bankruptcy Court sustained the objection, and the bank appealed.

 

On appeal from the bankruptcy court, the District Court first addressed the bankruptcy court's finding that the single signature of the former wife was unauthorized.  On this issue, the District Court held that the bankruptcy court erroneously relied upon a provision of the Virginia Code that had been amended in 2003, prior to the activity at issue.

 

The District Court also held that the bankruptcy court's finding that the debtor did not receive any benefit from the $20,000 in HELOC advances was clearly erroneous. The District Court noted that the former wife testified in bankruptcy proceedings that the money in the advances was used to settle debts, payments, and bills that the couple accumulated jointly when married.

 

In addition, the District Court noted that the debtor's testimony was not specific as all he testified to was that he was not aware the proceeds from the checks had been used to pay joint debts.  Moreover, the Court also noted that the debtor continued to pay interest on all of the withdrawals from the HELOC up until the time he filed the bankruptcy proceedings, and that the debtor also did not allege misuse of the HELOC withdrawal during the divorce proceedings.

 

Third, the District Court also held that the debtor's claim that the withdrawals were unauthorized was time-barred. The withdrawals occurred in July and September 2006 and the statute of limitations for a breach of contract in Virginia is five years. The defendant had until September 7, 2011 to file suit against the bank for breach of contract.

 

Lastly, District Court held that the statute of limitations bar could not be avoided by an argument that the debtor's claim against the bank to declare the withdrawal amounts unenforceable was in the nature of recoupment against the claim by the bank to recover those amounts. The District Court held that, in order for recoupment to apply, both the creditor's claim and the amount owed to the debtor must arise from a single contract or transaction.  

 

The District Court held that it was clear that more than a single contract of transaction was involved here, because the original HELOC agreement provided that credit could be given on the basis of a single signature from either the debtor or his ex-wife, and the "freeze" direction given by the debtor to the bank constituted a second transaction. Therefore, the District Court held, the doctrine of recoupment did not apply.

Accordingly, the order entered by the Bankruptcy Court was reversed.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Monday, June 20, 2016

FYI: OH Sup Ct Holds Fannie Mae Not Subject to "Penalties or Fines" While Under Conservatorship

In a putative class action alleging failure to timely record satisfactions of mortgages, the Supreme Court of Ohio recently held that a cease-and-desist order issued by the Federal Housing Finance Agency ("FHFA") to Federal National Mortgage Association ("Fannie Mae") did not preclude the trial court from exercising jurisdiction under the federal statute governing judicial review of FHFA orders.

 

However, the Court also held that a different federal law bars the trial court from ordering Fannie Mae to provide monetary relief under the Ohio statute at issue, while Fannie Mae is under FHFA's conservatorship, because the federal statute prohibits Fannie Mae from incurring liabilities "in the nature of penalties or fines" while under FHFA conservatorship.

 

A copy of the opinion is available at:  Link to Opinion

 

The plaintiff mortgagor filed a putative class action alleging that Fannie Mae supposedly failed to timely record in the appropriate county recover's office the satisfaction of her residential mortgage within 90 days after the payoff, as required under Ohio law.  The plaintiff and class members each sought to recover $250 under Ohio Revised Code section 5301.36(C), as well as any other legal remedies or damages that may be available to each putative class member.

 

The trial court certified a class of all persons who, since May 9, 1997, and thereafter, paid off an Ohio residential mortgage, where Fannie Mae was the mortgagee at the time of the payoff, and a satisfaction was not recorded with any Ohio county recorder within 90 days from the date of the payoff. The Eight District Court of Appeals affirmed the certification of the class.

 

During the class-certification proceedings, the Federal Housing Finance Agency ("FHFA") placed Fannie Mae under its conservatorship.  Fannie Mae then sought to remove the class action to federal court due to the conservatorship. The federal trial court denied Fannie Mae's removal petition and remanded the matter to the state court. 

 

Upon remand, FHFA issued a consent order requiring Fannie Mae to cease and desist from violating 12 U.S.C. §4617(j)(4) by paying any fines or penalties imposed by any state mortgage satisfaction law and paying any amount pursuant to Ohio Revised Code 5301.36 or pursuant to any judgment in connection with the pending lawsuit.

 

Fannie Mae then moved to dismiss for lack of subject matter jurisdiction alleging the class action would affect the FHFA's enforcement of the consent order in contravention of 12 U.S.C. 4635(b), which states that "no court shall have jurisdiction to affect, by injunction or otherwise, the issuance or enforcement of any notice or order under section 4631 [cease-and-desist orders] or to review, modify, suspend, terminate, or set aside any such notice or order".  Fannie Mae also argued that the consent order expressly prohibits it from paying any judgment in the matter.

 

The trial court dismissed the complaint for lack of subject matter jurisdiction. The Eighth District Court of Appeals reversed and held that the FHFA consent order did not divest the trial court of jurisdiction, and a judgment awarding statutory damages would not affect the FHFA consent order in contravention of 12 U.S.C. 4635(b).  The Eighth District also concluded that O.R.C. 5301.36(C) does not implicate the federal statute which immunizes Fannie Mae from incurring liabilities in the nature of a penalty and a fine, 12 U.S.C. § 4617(j)(4).

 

The Supreme Court of Ohio accepted Fannie Mae's appeal.

 

The Supreme Court of Ohio began its analysis by determining if the trial court had subject matter jurisdiction under 12 U.S.C. § 4635(b).  Subsection 4635(b) states: "no court shall have jurisdiction to affect, by injunction or otherwise, the issuance or enforcement of any notice or order under section 4631 or to review, modify, suspend, terminate, or set aside any such notice or order." This language mirrors the language in another section of the statute in which the United States Supreme Court concluded provides clear and convincing evidence that Congress intended to deny the district court's jurisdiction to review and enjoin an agency's ongoing administrative proceedings.

 

The Court noted that the jurisdictional bar is not meant to displace a non-party's right to present its claims to a court, or displace the jurisdiction of the court to hear those claims.  The Supreme Court of Ohio noted that 12 U.S.C. § 4635(b) allows a court to adjudicate state law claims against a regulated entity subject to a federal consent order so long as the exercise of such jurisdiction does not conflict with or contradict the terms of the consent order itself.

 

The Supreme Court of Ohio found that the FHFA consent order against Fannie Mae did not divest the trial court of jurisdiction. The Court noted that the terms of the consent order narrowly prohibited Fannie Mae from paying any amount pursuant to O.R.C. 5301.36 or pursuant to any judgment in connection with the pending lawsuit, and that the consent order did not preclude the trial court from issuing a judgment or determining that Fannie Mae violated state law.

 

Therefore, the Supreme Court of Ohio concluded that the FHFA consent order and 12 U.S.C. § 4635(b) do not bar the trial court from adjudicating the plaintiff's class action claims under O.R.C. 5301.36.

 

The Court then looked at the applicability of 12 U.S.C. § 4617(j)(4) to damages paid under the Ohio Revised Code. Subsection 4617(j)(4) states that while FHFA is acting as conservator, "the Agency shall not be liable for any amounts in the nature of penalties or fines, including those arising from the failure of any person to pay any real property, personal property, probate, or recording tax or any recording or filing fees when due." The Court noted that the FHFA succeeds to all the rights, titles, powers, and privileges of a regulated entity during conservatorship, and thus many courts have uniformly construed this section to preclude imposition of fees or penalties while under FHFA conservatorship.

 

The Supreme Court of Ohio determined that the question of whether Congress intended to waive Fannie Mae's immunity from state-law penalties implicates strong federal questions, and therefore turned to federal law to determine whether the $250 recovery from the plaintiff and class members constituted a penalty.

 

The Court noted that the federal test for determining whether a particular statutory provision is punitive or remedial consists of three factors: (1) whether the purpose of the statute as a whole primarily redresses individual wrongs or more general wrongs to the public, (2) whether recovery under the statute runs to the harmed individual or to the public, and (3) whether the recovery authorized by the statute is wholly disproportionate to the harm suffered.

 

In applying the above factors, the Supreme Court of Ohio concluded that the $250 awards under O.R.C. 5301.36(C) for failure to record a mortgage satisfaction would be in the nature of penalties and therefore may not be assessed against the defendant while under FHFA's conservatorship. 

 

The Court noted that the O.R.C. section is intended to promote efficiency and certainty in real estate transactions, and to penalize the untimely recording of satisfied mortgages. The Court also noted that the recovery of $250 is not tied to any actual losses suffered by an aggrieved individual and is an arbitrary figure.  The Court recited the general rules that damages are commensurate with the injury received, whereas penalties have no reference to the actual loss sustained by the individual who sued for recovery. Accordingly, the Court held, where statutory damages are allowed in addition to compensatory damages, as in this case, they are considered a penalty.

 

The Supreme Court of Ohio concluded that the $250 award under R.C. 5301.36(C) would be in the nature of a penalty without overruling or contradicting Rosette v. Countrywide Home Loans, 105 Ohio St.3d 296, 2005-Ohio-1736, 825 N.E.2d 599.

 

In Rosette, the Supreme Court of Ohio concluded that O.R.C. 5301.36(C) is a remedial rather than penal statute and therefore applied the six-year limitations period in R.C. 2305.07 for "a liability created by statute other than a forfeiture or penalty." The Court noted that the word "damages" in the O.R.C. was dispositive of the court's ruling in Rosette.  The Court distinguished Rosette because it addressed whether payments under O.R.C. 5301.36(C) should be labeled as penal or remedial for statute-of-limitations purposes.  Accordingly, the Court held, Rosette has no bearing on whether payments under O.R.C. 5301.36(C) are "in the nature of penalties" under 12 U.S.C. § 4617(j)(4), which requires a completely different test under federal law.

 

The Supreme Court of Ohio concluded that, because statutory sanctions can serve more than one purpose, the statutory remedy in O.R.C. 5301.36(C) vindicates both punitive and remedial purposes without disturbing the holding in Rosette.

 

The Supreme Court did not address the plaintiff's due process claim as the Eighth District explicitly declined to address it.

 

One justice concurred in judgment only stating the court of appeals' judgment should be affirmed in its entirety, not just technically.  One justice dissented asserting that the trial court was correct in dismissing the case for lack of jurisdiction.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Indiana   |   Maryland   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

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Sunday, June 19, 2016

FYI: 4th Cir Holds Arbitration Provision Enforceable Despite Change in Other Terms

The U.S. Court of Appeals for the Fourth Circuit recently held that an arbitration provision was enforceable under the Federal Arbitration Act, 9 U.S.C. §§ 1 et seq. ("FAA"), and under Maryland law, even though the arbitration provision appeared in an amended finance agreement that was not signed by the finance company, and even though additional terms in the amended finance agreement were later modified.

 

A copy of the opinion is available at:  Link to Opinion 

 

The plaintiff was the obligor on a retail installment sales contract (RISC) she obtained to finance the purchase of her vehicle.   The RISC listed the total amount financed as $22,916.28, requiring the plaintiff to make 72 payments of $487.46 monthly. The RISC also included a modification provision stating that any change to the contract must be in writing and signed by the finance company.

 

The RISC was sold and assigned to a finance company. The plaintiff subsequently requested a reduction in the amount of her monthly loan payment.  The finance company allegedly told her it would consider whether to approve her request and notify her in writing.

 

The finance company sent the plaintiff an amended agreement for her to sign and return for further review, approval, and consideration of her reduction request. The terms of the amended agreement reduced the monthly payment to $365.57 and included an arbitration provision. The plaintiff signed and sent the amended agreement to the finance company on November 12, 2008.

 

The monthly payments were eventually lowered to $366.43 -- 86 cents more than the amount contemplated in the amended agreement. The plaintiff began making payments of that amount and did so for several years.  In December 2011, the finance company sold and assigned the RISC to a second finance company, the defendant in this case.

 

The plaintiff eventually fell behind on her payments and the defendant repossessed the vehicle. The plaintiff then brought this action in state court, alleging that the defendant failed to provide required notices before selling the vehicle. The plaintiff sought to bring suit on behalf of herself and a class of all persons similarly situated.

 

The defendant removed the case to federal court and filed a motion to compel arbitration and stay federal district court proceedings under the Federal Arbitration Act ("FAA"), arguing that the plaintiff agreed to arbitrate any disputes concerning her loan.

 

The district court concluded that, as a matter of law, the plaintiff had agreed to arbitration and that the agreement to arbitrate was enforceable under the FAA, even though the RISC required that any change to the contract must be in writing and signed the finance company, and the finance company did not sign the amended agreement and the payment amounts actually made were different than what the amended agreement required.

 

The district court reasoned that the first finance company's sending of the amended agreement to the plaintiff was a mere invitation for the plaintiff to make an offer, because the company retained the right at that time to reject the plaintiff's refinancing application, even if she signed the agreement.  The district court concluded that the plaintiff's returning a copy of the executed agreement constituted an offer to enter into the agreement and that the finance company accepted that offer by reducing her monthly payments albeit in a different amount.

 

The district court also found that the finance company's proposal to reduce the payments to $366.43 constituted a counteroffer to make a minor modification to the dollar amounts in the amended agreement, which the plaintiff accepted by making payments in the requested amount for several years without objection.

 

The district court initially granted the defendant's motion to compel arbitration and stayed the case, but then on reconsideration dismissed the case as to allow the plaintiff to pursue an immediate appeal.

 

As you may recall, application of the FAA requires demonstration of four elements: (1) the existence of a dispute between the parties, (2) a written agreement that includes an arbitration provision which purports to cover the dispute, (3) the relationship of the transaction, which is evidenced by the agreement, to interstate or foreign commerce, and (4) the failure, neglect or refusal of the defendant to arbitrate the dispute.

 

Under Maryland contract law, there must be mutual assent between the parties in order to form a contract. A contract is formed when an unrevoked offer made by one person is accepted by another. An offer is a manifestation of willingness to enter into a bargain, so made as to justify another person in understanding that his assent to that bargain is invited and will conclude it. Acceptance may be manifested by actions as well as words.

 

Only the second element in the application of the FAA was at issue in this case. The plaintiff alleged that the district court erred in concluding the arbitration provision was a term of any enforceable contract and it erred in ruling the acceptance of that provision satisfied the FAA's writing requirement.

 

The Fourth Circuit first looked at whether the plaintiff was entitled to a jury trial regarding whether she and the financing company entered into a binding contract which included the arbitration agreement.

 

The Fourth Circuit found that the sending of the amended agreement by the finance company to the plaintiff was a mere invitation for the plaintiff to make an offer. Thus, the execution of the amended agreement and sending a copy of the signed document by the plaintiff to the finance company was an offer to the finance company to enter into the agreement.

 

The plaintiff argued that the finance company's actions were not an acceptance of her offer because, under Maryland law, any variation from the terms of the offer is considered as a counteroffer. Thus, according to the plaintiff, the new monthly payment price -- 86 cents more than shown in the amended agreement -- was a counter offer.  However, the Fourth Circuit followed the district court's holding that even if the actions were considered a counteroffer, the plaintiff accepted such terms by making payments of the slightly increased amount.

 

The plaintiff also argued that under Maryland law, the parties could not validly modify the RISC without setting out all of the new terms together in a written document, and signing the document. However, the Fourth Circuit held there was no term in the amended agreement that indicated the finance company's signature was necessary to bind the parties to the contract.

 

The Court noted that the only contractual language the plaintiff cited as the basis for her position that a written agreement signed by both parties was necessary to effectively modify the RISC was the language in the original RISC itself stating that any future amendment would need to be by a signed writing. However, the Fourth Circuit held that, under Maryland law, contractual limitations on future modifications are not effective to prevent parties from entering into new agreements orally or by performance; rather, they only provide context for interpreting subsequent conduct.

 

Here, the Fourth Circuit found, the parties' conduct left no doubt that they intended to modify the terms of the RISC, even in the absence of a signed writing memorializing all of the new terms to which they agreed.

 

Thus, the Fourth Circuit held that the district court properly concluded that the arbitration agreement was a term of the contract that the parties entered into.

 

The Fourth Circuit then looked to the plaintiff's argument that any arbitration agreement the parties entered into by their conduct was not enforceable under the FAA.  Specifically, the Court noted, the question was whether the parties' non-written modification of a separate term of the amended agreement rendered the arbitration agreement unenforceable under the FAA.

 

Following similar rulings in other federal courts of appeal, the Fourth Circuit held that the FAA's written arbitration agreement requirement is met by an actual document, but need not include any written assent to the obligations.

 

The Fourth Circuit held that, because the plaintiff assented to be bound by the amended agreement when she signed it and made payments, and because the arbitration provision in the amended agreement was in writing, it did not matter that she also assented to other modified terms as to the amount of the monthly payment that may not have been in writing.

 

Thus, the Fourth Circuit found that the district court was correct to enforce the arbitration agreement, and affirmed the district court's order dismissing the plaintiff's action.

 

One judge dissented on the grounds that the parties disputed what was agreed to and whether it was memorialized by a writing. Therefore, the dissenting judge noted, the plaintiff had shown there was a material fact in dispute and was entitled to have a jury decide the dispute.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia   |   Illinois   |   Indiana   |   Maryland   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments

 

and

 

Insurance Recovery Services