Oct 26, 2011 FIC Alliance â Week 13 ECOA VS HMDA - Action Taken
Oct 26, 2011
FIC Alliance – Week 13
ECOA VS HMDA - Action Taken Even if your Institution or Company is not covered by HMDA requiring you to comply with collection and reporting responsibilities, it is important to understand some differences between ECOA and HMDA when it comes to the Action Taken on a loan application.
Let’s first start with generally identifying who has to comply with the Home Mortgage Disclosure Act (HMDA) Regulation C. A federally insured or regulated Depository Institution which as of the preceding December 31st, had a home or branch office in a metropolitan area, AND Had assets of more than $40 million (this threshold can change annually), AND Originated in the preceding calendar year – a home purchase loan (other than temporary financing such as a construction loan) secured by a first lien on a one-to-four family dwelling. A home purchase loan can include the refinancing of a home purchase loan.
Coverage also extends to for-profit Institutions (not a Bank, Savings Institution or Credit Union which in the preceding calendar year, their home purchase loan originations (including refinancing of home purchase loans) equal or exceed 10 percent of its total loan originations, measured in dollars, or equal $25 million or more. AND if they had a home or branch office in a metropolitan area as of December 31, of the preceding calendar year, OR received applications for, originated, or purchased five or more home purchase loans, home improvement loans, or refinancing on property located in an MSA in the preceding calendar year. AND if they EITHER have total assets combined with those of the parent corporation that were more than $10 million as of the preceding December 31, OR they originate* 100 or more home purchase loans (including refinancing of home purchase loans) in the preceding calendar year. *To determine “origination” we must look to the discussion of the broker rule in the following section of the staff commentary. In section 203.1(c) in reference to the “broker rule” it states that when an institution takes or processes a loan application and arranges for another institution to acquire the loan at or after closing, it is acting as a “broker” and an institution that acquires a loan from a “broker” at or after closing is acting as an “investor.” Depending on the facts, a “broker” may or may not make a credit decision on an application (and thus it may or may not have reporting responsibilities). If the broker makes the credit decision, even when it is based on underwriting criteria set by an investor, WITHOUT the investor reviewing it prior to closing, the broker reports the decision. If instead an investor reviews an application and makes a credit decision prior to closing, the investor reports the credit decision. A ”broker” or an “investor” that makes a credit decision on an application prior to closing, reports that decision regardless of whose name the loan closes in.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 2
Now, that we have established who has collection and reporting responsibilities under HMDA, let’s clarify the differences in the “action taken” on applications for both HMDA and ECOA.
ECOA Notification of Action Taken 30 Days after receiving a completed application concerning approval, counteroffer or denial of the application 30 Days after taking adverse action on an incomplete application, unless a notice of incompleteness is provided 30 Days after taking adverse action on an existing account 90 Days after notifying the applicant of a counter offer, if applicant does not expressly accept or use the credit offered
HMDA – Types of Action under Action Taken B. Action Taken 1. Type of Action. Indicate the type of action taken on the application or loan by using one of the following codes: Code 1 - Loan originated Code 2 - Application approved but not accepted Code 3 - Application denied Code 4 - Application withdrawn Code 5 - File closed for incompleteness Code 6 - Loan purchased by your institution Code 7 - Preapproval request denied Code 8 - Preapproval request approved but not accepted (optional reporting)
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 3
Loan Originated Lenders should report loans under HMDA that the lender made the credit decision on and that closed within the same calendar year. Applications still pending at the end of the calendar year should not be reported until the year that the final action is taken. For a counteroffer (your offer to the applicant to make the loan on different terms or in a different amount from the terms or amount applied for), you would report this as a loan originated under HMDA – using code 1 - if the applicant accepts. For ECOA purposes in the case of a counteroffer, (your offer to the applicant to make the loan on different terms or in a different amount from the terms or amount applied for), you will again consider this a loan originated, if the applicant accepts the counteroffer and the loan closes. If a borrower rescinds a transaction after closing, the institution, on a case-bycase basis, may report the transaction either as an origination or as an application that was approved but not accepted.
Application Approved but NOT Accepted If an Institution approves a loan subject to customary loan-commitment or loanclosing conditions and the applicant does not meet one of these conditions or an analogous condition, this application is “Approved but not Accepted.” To clarify, customary loan-commitment or loan-closing conditions include “clear title” requirements, acceptable title insurance binder, clear termite inspection, acceptable property survey, and, where the applicant plans to use the proceeds from the sale of one home to purchase another, a settlement statement showing adequate proceeds from the sale. This code is used under HMDA when the application is approved but the applicant (or the loan broker or correspondent) fails to respond to your notification of approval or your commitment letter within a specified time. For ECOA purposes, it will be necessary to meet the retention requirements for a period of 25 months from the date of action taken. If a borrower rescinds a transaction after closing, the institution, on a case-bycase basis, may report the transaction either as an origination or as an application that was approved but not accepted.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 4
Application Denied Under ECOA, a Creditor must convey it’s credit decision at least 30 days after receiving a completed written or oral application. Adverse action must be in writing and contain at least the following as specified in 202.9b)(1) ECOA notice: 1. Name and address of the creditor 2. Statement of action taken 3. Statement of specific reasons or the right to receive the reasons within 30 days if the statement is requested within 60 days of the notification 4. Name and address of the federal agency administering compliance 5. Name, address and phone of consumer reporting agency 6. Statement that the consumer reporting agency was not responsible for the credit decision 7. Notice of the consumer’s right to a free copy of the credit report if requested within 60 days 8. Name, address and phone of other source if information contributed to the creditor’s decision to take adverse action. When a creditor makes a counteroffer, there is an exception to the 30 day rule. Most lenders find it a “best practice” to use a combination form containing the notice of adverse action and the notice of counteroffer. If the counteroffer is provided separately however; and the applicant doesn’t use the credit within 90 days after the creditor makes the counteroffer, the creditor must send an adverse action at that time. For example: If an institution makes a counteroffer to lend on terms different from the applicant's initial request (for example, for a shorter loan maturity or in a different amount) and the applicant does not accept the counteroffer or fails to respond, the institution reports the action taken as a denial on the original terms requested by the applicant. In the case of a Conditional Approval, an institution reports a “denial” if an institution approves a loan subject to underwriting conditions and the applicant does not meet them. Conditional approval may have been issued conditioned on underwriting conditions concerning the borrower’s creditworthiness, including debt to income and loan to value ratios; or possibly verification or confirmation, in whatever form the lender ordinarily requires, that the borrower meets underwriting conditions concerning the borrower’s creditworthiness. FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 5
ECOA retention requirements is again 25 months from the date of action taken and includes at least the following: Application (and any attachments thereto) Notification of Action Taken Statement of Specific Reasons for Adverse Action Any Written Statement submitted by the Applicant alleging a violation of the Act
Application Withdrawn If a credit decision has not been made and the borrower has expressly withdrawn, use the code for “application withdrawn.” This code under HMDA reporting is not otherwise available. Under ECOA/Reg B however, an applicant may choose to withdraw an approved application and it will not be coded as “application withdrawn” under HMDA reporting because a credit decision has already been made. For example under ECOA/Reg B: When an applicant submits an application and the parties contemplate that the applicant will inquire about its status, if the creditor approves the application and the applicant has not inquired within 30 days after applying, the creditor may treat this application as withdrawn and does not require any further notification to the applicant. It is always a good practice to follow up with applicants instead of waiting for them to follow up with you.
File Closed for Incompleteness If a credit decision has not been made and the lender makes a condition involving submitting additional information about creditworthiness the lender needs to make a credit decision and the applicant has not responded to a request for the additional information in the time allowed, use the code for "file closed for incompleteness.” The request for additional information is generally in the form of a written “Notice of Incompleteness” under section 202.9(c)(2) of Regulation B (Equal Credit Opportunity), however, a creditor has the option to make an oral request for information.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 6
Model Form C-6 Sample Notice of Incomplete Application and Request for Additional Information Date Creditor’s Name Address Telephone Number Dear Applicant: Thank you for your application for credit. The following information is needed to make a decision on your application: ___________________________________________________ ____________________________________________________________________________ We need to receive this information by ____(date)____. If we do not receive it by that date, we will regrettably be unable to give further consideration to your credit request. Sincerely,
For example, if approval is conditioned on a satisfactory appraisal and, despite notice of the need for an appraisal, the applicant declines to obtain an appraisal or does not respond to the lender's notice, then the application should be coded "file closed for incompleteness." If, on the other hand, the applicant obtains an appraisal but the appraisal does not support the assumed loan-to-value ratio and the lender is therefore not willing to extend the loan amount sought, then the lender must use the code for "application denied." If your request for additional information is made orally and the applicant does not provide the information, the creditor must provide the notice of action taken
Loan purchased by your institution An institution reports the loans that it purchased during the calendar year, but does not report loans that it declined to purchase.
Preapproval Request Denied Preapproval Requests with NO Property Identified The lender uses code '7' ("preapproval request denied") under "type of action" and code '1' ("preapproval was requested") under "request for preapproval." Approved Preapproval Requests with Identified Property When a borrower who has received a written commitment in response to a preapproval request identifies a property to the lender but the loan fails to originate, neither code '7' ("preapproval request denied") nor code '8' ("preapproval request approved but not FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 7
accepted") should be used, as the application has passed the preapproval stage. In the "request for preapproval" field, code '1' (preapproval was requested) must be used. For example: (1) an applicant submits a request for approval, (2) the request is granted in the form of a written commitment containing only the conditions specified in the regulation, (3) the applicant identifies a property, (4) the appraisal is less than the borrower anticipated and the lender is not willing to lend the amount stated in the commitment letter, and (5) the lender counteroffers with a lower loan amount but the borrower does not accept. In these circumstances, the lender would use code '3' in the "type of action" field ("application denied by financial institution") and code '1' in the "request for preapproval" field ("preapproval was requested"). For ECOA/Reg B purposes, a creditor has treated a preapproval request, with or without a property, is subject to adverse action, if after evaluating the information, the creditor decides that it will not approve the request for preapproval and communicates this to the consumer.
Preapproval Request Approved but not Accepted (optional reporting) Approved Preapproval Requests with NO Property Identified If the transaction is reported, the lender uses code '8' ("preapproval request approved but not accepted") under "type of action" and code '1' ("preapproval was requested") under "request for preapproval." Approved Preapproval Requests with Identified Property When a borrower who has received a written commitment in response to a preapproval request identifies a property to the lender but the loan fails to originate, neither code '7' ("preapproval request denied") nor code '8' ("preapproval request approved but not accepted") should be used, as the application has passed the preapproval stage. In the "request for preapproval" field, code '1' (preapproval was requested) must be used. For example: (1) an applicant submits a request for approval, (2) the request is granted in the form of a written commitment containing only the conditions specified in the regulation, (3) the applicant identifies a property, (4) the appraisal is less than the borrower anticipated and the lender is not willing to lend the amount stated in the commitment letter, and (5) the lender counteroffers with a lower loan amount but the borrower does not accept. In these circumstances, the lender would use code '3' in the "type of action" field ("application denied by financial institution") and code '1' in the "request for preapproval" field ("preapproval was requested").
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 8
A Guide to HMDA Reporting Regulation C – Home Mortgage Disclosure http://www.ffiec.gov/hmda/
Regulation B – eCFR Part 202 – Equal Credit Opportunity http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title12/12cfr202_main_02.tpl
Kimberly Lundquist FIC Conferences, Inc. 1150 N Loop 1604 W Suite 108-603 San Antonio, TX 78248
Tel 210.493.1761 Fax 210.493.9659 [email protected] www.ficconferences.com
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 9
FIC Alliance – Week 13
ECOA VS HMDA - Action Taken Even if your Institution or Company is not covered by HMDA requiring you to comply with collection and reporting responsibilities, it is important to understand some differences between ECOA and HMDA when it comes to the Action Taken on a loan application.
Let’s first start with generally identifying who has to comply with the Home Mortgage Disclosure Act (HMDA) Regulation C. A federally insured or regulated Depository Institution which as of the preceding December 31st, had a home or branch office in a metropolitan area, AND Had assets of more than $40 million (this threshold can change annually), AND Originated in the preceding calendar year – a home purchase loan (other than temporary financing such as a construction loan) secured by a first lien on a one-to-four family dwelling. A home purchase loan can include the refinancing of a home purchase loan.
Coverage also extends to for-profit Institutions (not a Bank, Savings Institution or Credit Union which in the preceding calendar year, their home purchase loan originations (including refinancing of home purchase loans) equal or exceed 10 percent of its total loan originations, measured in dollars, or equal $25 million or more. AND if they had a home or branch office in a metropolitan area as of December 31, of the preceding calendar year, OR received applications for, originated, or purchased five or more home purchase loans, home improvement loans, or refinancing on property located in an MSA in the preceding calendar year. AND if they EITHER have total assets combined with those of the parent corporation that were more than $10 million as of the preceding December 31, OR they originate* 100 or more home purchase loans (including refinancing of home purchase loans) in the preceding calendar year. *To determine “origination” we must look to the discussion of the broker rule in the following section of the staff commentary. In section 203.1(c) in reference to the “broker rule” it states that when an institution takes or processes a loan application and arranges for another institution to acquire the loan at or after closing, it is acting as a “broker” and an institution that acquires a loan from a “broker” at or after closing is acting as an “investor.” Depending on the facts, a “broker” may or may not make a credit decision on an application (and thus it may or may not have reporting responsibilities). If the broker makes the credit decision, even when it is based on underwriting criteria set by an investor, WITHOUT the investor reviewing it prior to closing, the broker reports the decision. If instead an investor reviews an application and makes a credit decision prior to closing, the investor reports the credit decision. A ”broker” or an “investor” that makes a credit decision on an application prior to closing, reports that decision regardless of whose name the loan closes in.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 2
Now, that we have established who has collection and reporting responsibilities under HMDA, let’s clarify the differences in the “action taken” on applications for both HMDA and ECOA.
ECOA Notification of Action Taken 30 Days after receiving a completed application concerning approval, counteroffer or denial of the application 30 Days after taking adverse action on an incomplete application, unless a notice of incompleteness is provided 30 Days after taking adverse action on an existing account 90 Days after notifying the applicant of a counter offer, if applicant does not expressly accept or use the credit offered
HMDA – Types of Action under Action Taken B. Action Taken 1. Type of Action. Indicate the type of action taken on the application or loan by using one of the following codes: Code 1 - Loan originated Code 2 - Application approved but not accepted Code 3 - Application denied Code 4 - Application withdrawn Code 5 - File closed for incompleteness Code 6 - Loan purchased by your institution Code 7 - Preapproval request denied Code 8 - Preapproval request approved but not accepted (optional reporting)
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 3
Loan Originated Lenders should report loans under HMDA that the lender made the credit decision on and that closed within the same calendar year. Applications still pending at the end of the calendar year should not be reported until the year that the final action is taken. For a counteroffer (your offer to the applicant to make the loan on different terms or in a different amount from the terms or amount applied for), you would report this as a loan originated under HMDA – using code 1 - if the applicant accepts. For ECOA purposes in the case of a counteroffer, (your offer to the applicant to make the loan on different terms or in a different amount from the terms or amount applied for), you will again consider this a loan originated, if the applicant accepts the counteroffer and the loan closes. If a borrower rescinds a transaction after closing, the institution, on a case-bycase basis, may report the transaction either as an origination or as an application that was approved but not accepted.
Application Approved but NOT Accepted If an Institution approves a loan subject to customary loan-commitment or loanclosing conditions and the applicant does not meet one of these conditions or an analogous condition, this application is “Approved but not Accepted.” To clarify, customary loan-commitment or loan-closing conditions include “clear title” requirements, acceptable title insurance binder, clear termite inspection, acceptable property survey, and, where the applicant plans to use the proceeds from the sale of one home to purchase another, a settlement statement showing adequate proceeds from the sale. This code is used under HMDA when the application is approved but the applicant (or the loan broker or correspondent) fails to respond to your notification of approval or your commitment letter within a specified time. For ECOA purposes, it will be necessary to meet the retention requirements for a period of 25 months from the date of action taken. If a borrower rescinds a transaction after closing, the institution, on a case-bycase basis, may report the transaction either as an origination or as an application that was approved but not accepted.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 4
Application Denied Under ECOA, a Creditor must convey it’s credit decision at least 30 days after receiving a completed written or oral application. Adverse action must be in writing and contain at least the following as specified in 202.9b)(1) ECOA notice: 1. Name and address of the creditor 2. Statement of action taken 3. Statement of specific reasons or the right to receive the reasons within 30 days if the statement is requested within 60 days of the notification 4. Name and address of the federal agency administering compliance 5. Name, address and phone of consumer reporting agency 6. Statement that the consumer reporting agency was not responsible for the credit decision 7. Notice of the consumer’s right to a free copy of the credit report if requested within 60 days 8. Name, address and phone of other source if information contributed to the creditor’s decision to take adverse action. When a creditor makes a counteroffer, there is an exception to the 30 day rule. Most lenders find it a “best practice” to use a combination form containing the notice of adverse action and the notice of counteroffer. If the counteroffer is provided separately however; and the applicant doesn’t use the credit within 90 days after the creditor makes the counteroffer, the creditor must send an adverse action at that time. For example: If an institution makes a counteroffer to lend on terms different from the applicant's initial request (for example, for a shorter loan maturity or in a different amount) and the applicant does not accept the counteroffer or fails to respond, the institution reports the action taken as a denial on the original terms requested by the applicant. In the case of a Conditional Approval, an institution reports a “denial” if an institution approves a loan subject to underwriting conditions and the applicant does not meet them. Conditional approval may have been issued conditioned on underwriting conditions concerning the borrower’s creditworthiness, including debt to income and loan to value ratios; or possibly verification or confirmation, in whatever form the lender ordinarily requires, that the borrower meets underwriting conditions concerning the borrower’s creditworthiness. FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 5
ECOA retention requirements is again 25 months from the date of action taken and includes at least the following: Application (and any attachments thereto) Notification of Action Taken Statement of Specific Reasons for Adverse Action Any Written Statement submitted by the Applicant alleging a violation of the Act
Application Withdrawn If a credit decision has not been made and the borrower has expressly withdrawn, use the code for “application withdrawn.” This code under HMDA reporting is not otherwise available. Under ECOA/Reg B however, an applicant may choose to withdraw an approved application and it will not be coded as “application withdrawn” under HMDA reporting because a credit decision has already been made. For example under ECOA/Reg B: When an applicant submits an application and the parties contemplate that the applicant will inquire about its status, if the creditor approves the application and the applicant has not inquired within 30 days after applying, the creditor may treat this application as withdrawn and does not require any further notification to the applicant. It is always a good practice to follow up with applicants instead of waiting for them to follow up with you.
File Closed for Incompleteness If a credit decision has not been made and the lender makes a condition involving submitting additional information about creditworthiness the lender needs to make a credit decision and the applicant has not responded to a request for the additional information in the time allowed, use the code for "file closed for incompleteness.” The request for additional information is generally in the form of a written “Notice of Incompleteness” under section 202.9(c)(2) of Regulation B (Equal Credit Opportunity), however, a creditor has the option to make an oral request for information.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 6
Model Form C-6 Sample Notice of Incomplete Application and Request for Additional Information Date Creditor’s Name Address Telephone Number Dear Applicant: Thank you for your application for credit. The following information is needed to make a decision on your application: ___________________________________________________ ____________________________________________________________________________ We need to receive this information by ____(date)____. If we do not receive it by that date, we will regrettably be unable to give further consideration to your credit request. Sincerely,
For example, if approval is conditioned on a satisfactory appraisal and, despite notice of the need for an appraisal, the applicant declines to obtain an appraisal or does not respond to the lender's notice, then the application should be coded "file closed for incompleteness." If, on the other hand, the applicant obtains an appraisal but the appraisal does not support the assumed loan-to-value ratio and the lender is therefore not willing to extend the loan amount sought, then the lender must use the code for "application denied." If your request for additional information is made orally and the applicant does not provide the information, the creditor must provide the notice of action taken
Loan purchased by your institution An institution reports the loans that it purchased during the calendar year, but does not report loans that it declined to purchase.
Preapproval Request Denied Preapproval Requests with NO Property Identified The lender uses code '7' ("preapproval request denied") under "type of action" and code '1' ("preapproval was requested") under "request for preapproval." Approved Preapproval Requests with Identified Property When a borrower who has received a written commitment in response to a preapproval request identifies a property to the lender but the loan fails to originate, neither code '7' ("preapproval request denied") nor code '8' ("preapproval request approved but not FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 7
accepted") should be used, as the application has passed the preapproval stage. In the "request for preapproval" field, code '1' (preapproval was requested) must be used. For example: (1) an applicant submits a request for approval, (2) the request is granted in the form of a written commitment containing only the conditions specified in the regulation, (3) the applicant identifies a property, (4) the appraisal is less than the borrower anticipated and the lender is not willing to lend the amount stated in the commitment letter, and (5) the lender counteroffers with a lower loan amount but the borrower does not accept. In these circumstances, the lender would use code '3' in the "type of action" field ("application denied by financial institution") and code '1' in the "request for preapproval" field ("preapproval was requested"). For ECOA/Reg B purposes, a creditor has treated a preapproval request, with or without a property, is subject to adverse action, if after evaluating the information, the creditor decides that it will not approve the request for preapproval and communicates this to the consumer.
Preapproval Request Approved but not Accepted (optional reporting) Approved Preapproval Requests with NO Property Identified If the transaction is reported, the lender uses code '8' ("preapproval request approved but not accepted") under "type of action" and code '1' ("preapproval was requested") under "request for preapproval." Approved Preapproval Requests with Identified Property When a borrower who has received a written commitment in response to a preapproval request identifies a property to the lender but the loan fails to originate, neither code '7' ("preapproval request denied") nor code '8' ("preapproval request approved but not accepted") should be used, as the application has passed the preapproval stage. In the "request for preapproval" field, code '1' (preapproval was requested) must be used. For example: (1) an applicant submits a request for approval, (2) the request is granted in the form of a written commitment containing only the conditions specified in the regulation, (3) the applicant identifies a property, (4) the appraisal is less than the borrower anticipated and the lender is not willing to lend the amount stated in the commitment letter, and (5) the lender counteroffers with a lower loan amount but the borrower does not accept. In these circumstances, the lender would use code '3' in the "type of action" field ("application denied by financial institution") and code '1' in the "request for preapproval" field ("preapproval was requested").
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 8
A Guide to HMDA Reporting Regulation C – Home Mortgage Disclosure http://www.ffiec.gov/hmda/
Regulation B – eCFR Part 202 – Equal Credit Opportunity http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title12/12cfr202_main_02.tpl
Kimberly Lundquist FIC Conferences, Inc. 1150 N Loop 1604 W Suite 108-603 San Antonio, TX 78248
Tel 210.493.1761 Fax 210.493.9659 [email protected] www.ficconferences.com
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 26, 2011 – Week 13 Page 9
