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| Iowa Mortgage Association - Prime Times Nov 18, 2009 In this issue: President's Message 2010 Membership Drive Save the Date for Upcoming IMA Loan Originator Workshop First-time Homebuyer Tax Credit Extended HUD Announces Moratorium in Enforcement of New RESPA Rules FHA Delays Implementation of New Condo Rules USDA Rural Development Receives Fiscal Year 2010 Budget Funding Fed Issues Clarification on Short-Term Balloon Loans and HOEPA Mortgage Loan Originator Registration Rule to Be Finalized FDIC issues FIL on Protecting Tenants at Foreclosure Act New Consumer Advisory on Reverse Mortgages Fannie Mae Announces Deed for Lease Program RESPA Revisions 202 President's Message President's Message  2009-10 IMA President Kathy Klahn Hello fellow IMA members: Hope you are all having a great fall! Great news! President Obama has signed the extension for the first-time homebuyer $8000 tax credit, extending the credit for purchase offers signed by April 30, 2010 and closed by July 1, 2010. In addition, those that have owned a home for at least five years maybe eligible for up to $6500 in a tax credit during the same timeframe should they buy a different home. The tax credit is determined by their income and the sale price of the home. It seems we are continuously buried in all the new regulations and changes that keep coming at us like a freight train. Between Reg. Z delivery date changes, Reg Z. higher-priced mortgage procedures, the new registration and licensing requirements and RESPA changes coming down the pike, many lenders state they work in fear of making the wrong move. We must keep a positive attitude knowing it will someday payoff by narrowing down the number of lenders to those that are knowledgeable and willing to stay current on the regulations and are in the business for the right reasons. It is the strong become stronger theory. With that being said, I hope you all had the opportunity to sign up for the RESPA educational seminars. Teresa Carley Brown does an outstanding job chairing the education committee, and we are deeply appreciative of Teresa and the entire committee's time and effort spent choosing seminars that fit our current needs. The real estate industry has had so many changes in the almost 36 years I have been involved, but the more recent changes have been extraordinarily brutal. Partially because there are so many changes you barely have time to grasp the last one before another comes at you. Between constant loan level pricing and program changes at Fannie Mae they also really keep us on our toes. Hopefully you all will weather the storm and look at it as working to make our industry stronger, but if you find you have some time on your hands this winter please consider preparing for and taking the test to become an Iowa Certified Mortgage Professional. It is very rewarding as a mortgage lender to achieve this accomplishment. If I can ever be of any help to any of you please let me know. In the meantime, keep striving to be the best mortgage lender you can possibly be and it will pay dividends in the end. Sincerely, Kathy Klahn 2010 Membership Drive 2010 Membership Drive Be on the lookout for your IMA renewal for 2010! Renewal forms will be in the mail in late November and are also available on the IMA website at www.iowama.org. The IMA is planning another great year, continuing to make significant strides to improve the mortgage industry. We encourage to you join forces with your fellow mortgage professionals and take advantage of all the IMA has to offer. Save the Date for Upcoming IMA Loan Originator Workshop Save the Date for Upcoming IMA Loan Originator WorkshopJanuary 26, 2010 2010 IMA Loan Originator Workshop 9:00 - 4:00 p.m. Stoney Creek Inn, Johnston First-time Homebuyer Tax Credit Extended First-time Homebuyer Tax Credit Extended  On Nov. 6, President Obama signed the Worker, Homeownership and Business Assistance Act of 2009 into law, extending and expanding the first-time homebuyer credit. The new law:
For the first time, long-time homeowners who buy a replacement principal residence may also claim a homebuyer credit of up to $6,500 (up to $3,250 for a married individual filing separately). They must have lived in the same principal residence for any five-consecutive year period during the eight-year period that ended on the date the replacement home is purchased. People with higher incomes can now qualify for the credit. The new law raises the income limits for homes purchased after Nov. 6, 2009. The credit phases out for individual taxpayers with modified adjusted gross income (MAGI) between $125,000 and $145,000 or between $225,000 and $245,000 for joint filers. The existing MAGI phase-outs of $75,000 to $95,000 or $150,000 to $170,000 for joint filers still apply to purchases on or before Nov. 6, 2009. As a reminder, the first-time homebuyer tax credit:
“At a time when we are finally starting to see some signs of life in the housing and mortgage markets, extending and expanding the homebuyer tax credit is a critical step to keeping the momentum. This has been one of MBA’s top single family legislative priorities, and we are very glad to see that policymakers on both sides of the aisle see the importance of this measure," he said. “The existing credit for first-time homebuyers has helped move a segment of potential homebuyers off the sidelines and into their first homes. By expanding it to qualified existing homeowners, we can help stimulate even more home purchases for qualified buyers. I also want to applaud measures in the bill that will help eliminate fraudulent use of the tax credit," Story added. In response to the extension of the of the first-time homebuyer tax credit, the IRS has created question and answer pages available online at http://www.irs.gov/newsroom/article/0,,id=187935,00.htmlHUD Announces Moratorium in Enforcement of New RESPA Rules HUD Announces Moratorium in Enforcement of New RESPA RulesOn Friday, Nov. 13, the Department of Housing and Urban Development (HUD) said it would "exercise restraint" in enforcing the new Real Estate Settlement Procedures Act (RESPA) rules for the first four months of 2010. HUD's general counsel also has sent a letter asking other federal and state enforcement agencies to exercise similar restraint with non-FHA originators and other settlement service providers. Such "restraint in enforcement" means that HUD is imposing a four-month moratorium in enforcing the new rules. Lenders still must demonstrate a good faith effort to comply with RESPA's new requirements, which are scheduled to take full effect on January 1. "Good faith effort" will be determined by whether the mortgagee has relied on the new RESPA rule and other written guidance issued by the department. The announcement follows efforts by the American Bankers Association (ABA), Mortgage Bankers Association (MBA) and other trade groups who have strongly encouraged HUD to address the problems associated with the controversial RESPA rules, first proposed in March 2008 and finalized last November. In letters to Congress, meetings with the Office of Management and Budget and countless conversations with HUD staff, ABA has pointed out areas of confusion, sought guidance and warned that the industry would have great difficulty complying by January 1. "We appreciate that HUD has recognized that there are severe implementation difficulties involved with this rulemaking," said ABA EVP Bob Davis. "We must remember, however, that notwithstanding the sincerest efforts of banks, high burdens in complying with this rule persist." Davis emphasized that this HUD pronouncement is not a delay in the rule, but rather, a temporary suspension of enforcement. "As such, banks must redouble their efforts to implement all the new requirements as finalized by HUD," he added. The MBA was also pleased with HUD's recent announcement. “We are pleased that HUD officials are recognizing the challenges that lenders are facing in implementing the new RESPA requirements. We look forward to continuing to work with HUD to gain more clarity around the new requirements and we hope that other federal and state officials will also heed HUD’s request that they exercise the same restraint," said MBA president and CEO John A. Courson. Read the HUD Press release at: http://portal.hud.gov/portal/page/portal/HUD/press/press_releases_media_advisories/2009/HUDNo.09-215For more information about the new RESPA rules, see the "RESPA Revisions 202" article in this issue of IMA's Prime Times. FHA Delays Implementation of New Condo Rules FHA Delays Implementation of New Condo RulesThe Mortgage Bankers Association says the FHA will delay implementation of new condo rules until Dec. 7, having already pushed the original Oct. 1 implementation date back to Nov. 2. MBA says the rules will be revised, eliminating recertification requirements for condo projects already on the FHA approved list and allowing the agency to insure up to 50 percent of all loans in a condo project and as many as 100 percent of units in "well established" projects with at least 10 percent reserves. However, the FHA still will require 50 percent of units to be sold to owner-occupants as a condition for backing. USDA Rural Development Receives Fiscal Year 2010 Budget Funding USDA Rural Development Receives Fiscal Year 2010 Budget FundingAfter a slight delay, USDA Rural Development's fiscal year 2010 guaranteed home loan funds are now available. The new 2010 budget offers the agency $12 billion in guaranteed funds nationwide, compared to slightly more than $6 billion last year. Also, this 2010 budget number does not include remaining funds made available through the American Recovery and Reinvestment Act (ARRA) and to help rural Iowans recover from flooding and natural disasters in 2008. Fiscal year 2010 funds have been released and full funding is now available to obligated conditional commitments. If you would like to get regular updates about news and information from USDA Rural Development in Iowa please contact Linda Rhoades at (515) 284-4666 or Linda.Rhoades@ia.usda.gov.You can also sign up for a free List Service originated from the National USDA Rural Development Office by visiting www.rdlist.sc.egov.usda.gov, checking the updates you wish to receive and clicking "Subscribe." This service provides instant program updates for guaranteed loan origination, guaranteed underwriting system and guaranteed loan servicing.
Fed Issues Clarification on Short-Term Balloon Loans and HOEPA Fed Issues Clarification on Short-Term Balloon Loans and HOEPAOn Nov. 9, the Federal Reserve issued FAQs regarding compliance with Regulation Z's repayment ability rule for higher-priced balloon mortgage loans. The FAQs clarify that the new HOEPA rules do not ban higher-priced balloon loans with terms of less than seven years, and that creditors do not have to verify that the consumer has assets and/or income at the time of consummation that would be sufficient to pay the balloon payment when it comes due. "Creditors extending balloon loans with terms of seven years or more can have a presumption of compliance if the procedures are followed and, if so, the creditor need not consider the borrower's ability to repay the balloon payment," the Fed said. "However, for some products a creditor cannot have a presumption of compliance even if it follows the specified procedures-these products include balloon loans with terms of less than seven years ("short-term balloon loans")." For such loans, lenders must assure that the borrower is likely to be able to satisfy the balloon payment obligation by refinancing the loan," which can be done by considering "factors such as the loan-to-value ratio and the borrower's debt-to-income ratio or residual income-all as of the time of consummation." The Fed's FAQs are available online at http://www.federalreserve.gov/boarddocs/caletters/2009/0912/caltr0912.htmMortgage Loan Originator Registration Rule to Be Finalized Mortgage Loan Originator Registration Rule to Be FinalizedThe FDIC Board of Directors has approved draft final rules implementing the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act). The rule has been posted on the FDIC's Web site, but will not be published in the Federal Register until the other agencies (OCC, OTS, FRB, FCA, NCUA) involved in this rulemaking complete their review and approval of the rule. The FDIC's approval of this draft final rule does not, therefore, mandate immediate registration requirements for mortgage loan originators. The duty to register will be fully finalized only upon publication of the joint rule in the Federal Register. FDIC clarified that to the extent there are differences between the attached draft final rule and the version ultimately published by the agencies in the Federal Register, FDIC will highlight those changes in a revised Financial Institutions Letter. The registry is required by the Secure and Fair Enforcement for Mortgage Licensing Act of 2008. The final draft rule approved by FDIC addresses a great number of the concerns expressed by the American Bankers Association (ABA) in its July 2009 comment letter. The definition of "mortgage loan originator," for instance, excludes employees who only assist in the loan process, as well as those engaged in loan modifications or assumptions. In addition, FDIC listened to ABA's request to permit batch processing of registrations, and placing common sense limits on bank liabilities regarding oversight of loan originators. The final rule exempts employees who originate five or fewer residential mortgage loans a year, as long as they have never been registered as a mortgage loan originator. The agencies also clarified that the 180-day implementation period for initial registrations will begin on a date to be specified in a public notice once the registry is available. The system is not expected to be available to accept registrations until sometime in 2010. FDIC issues FIL on Protecting Tenants at Foreclosure Act FDIC FIL on “Protecting Tenants at Foreclosure Act”On September 28, the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter regarding the Protecting Tenants at Foreclosure Act. The Act provides protections for tenants living in homes subject to foreclosure and requires creditors to provide tenants with 90-days notice before evicting those tenants as the result of a foreclosure. Additionally, in the event a foreclosure takes place, the Act obliges creditors to honor existing leases with renters until the end of their terms, subject to certain exceptions. These provisions will not preempt the requirements of any state or local law that provides longer time periods or other additional protections for tenants in homes subject to foreclosure. The letter clarifies these new requirements and verifies that protections under the Act became effective May 20, 2009. For a copy of the Financial Institution Letter, go to http://www.fdic.gov/news/news/financial/2009/fil09056.pdf.New Consumer Advisory on Reverse Mortgages New Consumer Advisory on Reverse MortgagesThe Office of the Comptroller of the Currency (OCC) issued a consumer advisory to help consumers better understand reverse mortgages. The information developed for consumers discusses basic facts about reverse mortgages, which are complex, home-secured loans. The advisory also reviews the costs and benefits of reverse mortgages. In addition, the OCC’s consumer advisory provides basic “rules of thumb” for consumers who are considering a reverse mortgage, including, for instance, urging consumers to investigate other alternatives in addition to reverse mortgages. “Reverse Mortgages: Are They for You?” is available on the OCC’s website at http://www.occ.gov/ftp/ADVISORY/2009-2.html.Fannie Mae Announces Deed for Lease Program Fannie Mae Announces Deed for Lease ProgramFannie Mae announced that it is implementing the Deed for Lease™ Program under which qualifying homeowners facing foreclosure will be able to remain in their homes by signing a lease in connection with the voluntary transfer of the property deed back to the lender. According to Fannie, the Deed for Lease Program provides "an additional option for qualifying homeowners who are facing foreclosure and are not eligible for modifications." The new program would help eliminate uncertainty of foreclosure, keep families and tenants in their homes and help stabilize neighborhoods and communities. The new program is designed for borrowers who do not qualify for or have not been able to sustain other loan-workout solutions, such as a modification. Under Deed for Lease, borrowers transfer their property to the lender by completing a deed in lieu of foreclosure, and then lease back the house at a market rate To participate in the program, borrowers must live in the home as their primary residence and must be released from any subordinate liens on the property. Tenants of borrowers in this circumstance may also be eligible for leases under the program. Borrowers or tenants interested in a lease must be able to document that the new market rental rate is no more than 31% of their gross income. Leases under the new program may be up to 12 months, with the possibility of term renewal or month-to-month extensions after that period. A Deed for Lease property that is subsequently sold includes an assignment of the lease to the buyer. For additional information about the Deed for Lease Program, including full details on program eligibility, please review the Guide Announcement on www.efanniemae.com.RESPA Revisions 202 RESPA Revisions 202 By Ronette Schlatter, CRCM Editor’s Note: This article is the second in a series of three discussing the revisions to RESPA effective as of January 1, 2010. The first article appeared in the October 2009 issue of "The Disclosure," the Iowa Bankers Association's Compliance magazine. The first article in the series discussed the revised definition of “application” for purposes of triggering the Good Faith Estimate (GFE) disclosure to applicants; RESPA’s fee restriction; the binding effect of the GFE; and the concept of “changed circumstances” which permit a lender to issue a revised GFE. This article will discuss the proper completion of the new GFE, while the third article, to be included in the December 2009 issue of The Disclosure, will address proper completion of the HUD settlement statement. This summary is based upon the instructions for completing the GFE as found in the November 17, 2008 Federal Register at http://edocket.access.gpo.gov/2008/pdf/E8-27070.pdf and HUD’s Questions and Answers (Q&A) on the RESPA revisions as found at http://www.hud.gov/offices/hsg/ramh/res/respa_hm.cfm.The lender is ultimately responsible for providing the GFE to an applicant within three days of receiving an application for a residential mortgage transaction. All lenders must use the revised standardized format for the GFE effective for applications received on or after January 1, 2010. So, regardless what loan platform a lender uses, the GFE should be the same format from one lender to the next. The GFE must be completed according to Instructions in Appendix C of Reg. X, which have changed dramatically from HUD’s current instructions for GFE completion. GFE TolerancesThe estimates provided on the GFE will be subject to “tolerance” levels as of January 1st. HUD has established maximum amounts by which the actual charges for a category or categories of settlement costs on the HUD settlement statement can exceed the amount estimated for that category (or categories) on the GFE. (Perhaps, the GFE should have been renamed the “GFG” - Good Faith Guarantee.) Those fees that the lender typically has control of, such as the origination charges, are subject to 0% tolerance; meaning the actual charges at settlement may not exceed the amounts disclosed on the GFE. Once the borrower’s interest rate is locked, the credit or charge for the interest rate chosen, the adjusted origination charge and transfer taxes also may not change. A 10% tolerance threshold is applied to the sum of the charges at settlement for the following services (that is, the sum amount of these services on the HUD statement may not be greater than 10 percent above the sum of the amounts included on the GFE):
As detailed earlier in the October Disclosure Feature article, the lender is bound to the costs disclosed on the GFE, within the applicable tolerance levels, unless a “changed circumstance” occurs. If a changed circumstance occurs affecting the loan, settlement costs or upon the borrower’s request, the lender may issue a revised GFE. If the lender elects to issue a revised GFE due to a changed circumstance, he/she must do so within three business days of receiving information sufficient to establish the change. The only costs that can be adjusted on the revised GFE are those directly related to the changed circumstance and the lender must retain documentation evidencing the changed circumstances and subsequent adjustments to the GFE for a period of three years after loan settlement. (See the October Disclosure Feature for a more detailed discussion of “changed circumstances.” Important DatesThe first page of the GFE provides the borrower with basic information about the loan including lender contact information as well as the purpose of the GFE. It also provides information about several important dates in the mortgage loan process. The first date discussed is the date the stated interest rate is available through. The instructions state the lender should state the date and, if necessary, time until which the interest rate for the GFE will be available. HUD’s Q&A explain there are no restrictions on the amount of time the interest rate must remain available. So for example, in volatile rate markets, a lender may find it necessary to state a rate is available through noon the same day the GFE is issued. HUD’s Q&A also indicate if a lender does not offer a rate lock or if a rate is not available for any period of time, the lender should indicate “NA” or “Not Applicable.” On Line 2 the lender is to state the date until which the estimate of all other settlement charges on the GFE will be available. According to Reg. X, this must be at least 10 business days (Monday through Saturday less legal holidays) from the date the GFE is provided to the borrower. If the GFE is mailed to the borrower, it is considered “provided” on the date it is placed in the mail. In Line 3 the lender must state how many calendar days within which the applicant must go to settlement once the interest rate is locked. Again, if lender does not offer a rate lock, enter “NA.” This date will likely vary from product to product and even loan to loan depending on the lender’s policy, rate lock periods with investors, etc. Line 4 should state how many calendar days prior to settlement the interest rate must be locked, if applicable. If a lender does not offer a rate lock, enter “NA.” HUD’s Q&A offer additional insight on how to adjust dates in the event a changed circumstance results in providing a revised GFE as well as how to handle the disclosure of the important dates when a mortgage broker and lender are both involved in a transaction. Summary of Your LoanThe remainder of the first page of the GFE provides a loan summary of sorts, largely repeating information provided in the early TIL and ARM program disclosure. Included in the loan summary table is:
Page 2 – Cost Estimates Page two of the GFE contains the breakdown of settlement costs. The manner in which fees are disclosed is dramatically different on the revised GFE. Costs are disclosed in 11 blocks or categories on the GFE. Additional lines be added to Blocks 3 (Required services we select), 6 (Required services you can shop for) and 11 (Homeowner’s Insurance) on the GFE, but not elsewhere. HUD’s Q&A state in several places the GFE should reflect costs “typically” incurred by the borrower. If at the time the GFE is issued it is known that the seller or another party will pay settlement charges typically paid by the borrower, the charges should still be included on the GFE. Another major change to completion of the GFE is that no items may be listed as POC (Paid Outside of Closing) on the GFE. HUD’s Q&A explain that if typical borrower costs were disclosed as POC or paid by a party other than the borrower and thus, not included in the totals, the information would not be as helpful to borrowers in shopping for a loan and would not facilitate comparison of charges on the GFE with charges on the HUD-1. Block 1 – Our Origination Charge
Block 2 – Your credit or charge for specific interest rate chosen When a mortgage broker is involved in the transaction, the broker must indicate:
Block 2 is also used to disclose lender credits for “No Cost” loans. If the ‘‘No Cost’’ loan includes third party fees as well as loan originator fees, all third party fees must be listed in Blocks 3–11. The lender is then to disclose a credit in Block 2 to offset all fees covered by the “no cost” offering resulting in a negative number in Block A to cover all fees listed in Blocks 3–11. Block 3 – Required services we select
One important note: Block 3 can be used for third party fees only; if the loan originator conducts a service that could be provided by a third party, such as an appraisal, title search or loan closing and charges a fee for the service, that fee must be included in Block 1 – the lender’s origination charge. The sum of the charges shown in this block is subject to an overall 10% tolerance. Block 4 – Title services and lender’s title insurance Keep in mind, the definition of “title services” includes:
Block 5 – Owners title insurance For purchase transactions, the lender must estimate the charge for the owner’s title insurance and related endorsements, regardless of whether the providers are selected or paid for by the borrower, seller or loan originator. Note: If the lender is using Title Guaranty provided by the Iowa Finance Authority, there is no additional fee for the Owner’s Policy for Title Guaranty. In this case, lenders must enter $0 to indicate there is no additional fee for the owner’s policy. Non-purchase transactions should enter ‘‘NA’’ or ‘‘Not Applicable’’ in Block 5. The charge shown in this block is subject to an overall 10% tolerance. Block 6 – Required services you can shop for The lender is required to provide the borrower with a written list of settlement services providers offering the service for which the borrower is permitted to shop. The lender may allow the borrower to shop for providers for services listed in Blocks 4, 5 or 6. However, the estimated costs for all Title Services must be detailed in Block 4 and the estimate for Owners Title Insurance must be disclosed in Block 5. This “recommended provider list” is to be provided on a separate sheet of paper with the GFE. HUD does not specify how many providers must be identified nor does it specify what information must be on the list — we assume name and contact information. In a recent OTS/HUD telephone conference call, a HUD representative indicated the intent behind the list is to provide a basis for the consumer as to how the estimates were made. Additional information can be added to this list including an explanation of the purpose of the list. For example, the lender may want to include prefacing remarks to the list indicating: “This list contains providers for settlement service for which you may shop. We do not require you use a specific provider. The estimates provided on the GFE are based the following settlement service provider’s typical fees but actual costs may vary. Again, we do not require you use the providers detailed below nor do we recommend or warrant the work of the listed providers.” If the borrower selects a lender-identified provider for the settlement service, the charge for service is subject to the 10% tolerance. If the borrower selects a provider not identified by the lender, no tolerance is applied to the charge. This could present a compliance challenge to lenders for purposes of staying within the 10% tolerance. Lenders are likely to only recommend providers who have consistent pricing structures or may opt to require all providers rather than letting borrowers shop for certain services. Block 7 – Government recording charges Block 8 – Transfer taxes Iowa lenders are reminded that Iowa Code requires transfer taxes to be paid by the seller. See Iowa Code chapter 535.8(b)(2): “The lender shall not charge the borrower for the cost of revenue stamps or real estate commissions which are paid by the seller.” Block 9 – Initial deposit for your escrow account You will notice there is no place on the GFE to enter annual property tax amounts. It would appear HUD’s intent is to only require disclosure of amounts required to be paid into an escrow account for purposes of disclosing property taxes. The amount in this block is not subject to any tolerance and may change. Block 10 - Daily interest charges The amount in this block is not subject to any tolerance and may change. Block 11 – Homeowner’s insurance If a loan originator requires that homeowner’s insurance be part of an escrow account, the amount of the initial escrow deposit must be included in Block 9, “Initial Deposit for Escrow.” Page 3The third page of the GFE provides instructional information to the borrower related to the various tolerance levels as well as “trade off” information. The “trade off” table can be used to illustrate to the borrower the effect of selecting a higher interest rate that would result in lower settlement costs or selecting a lower interest rate, which would in turn increase the borrower’s settlement costs. Interestingly enough, the lender is only required to complete the first column of the tradeoff table which summarized the loan amount, initial interest rate, initial monthly amount owed and total estimated charges for the interest rate disclosed on the GFE. Completion of columns two and three illustrating the effect of a lower and higher rate is optional. Finally, at the end of the GFE a “shopping chart” is provided in which the borrower can fill in information provided on various GFEs the borrower has collected during their mortgage loan shopping process in order to compare the GFEs more easily. (I know, I know. Borrowers are about as likely to use this tool as they are to read their Settlement Booklet or ARM program disclosure!) Transitions RulesHUD’s Q&A reiterate use of the revised GFE is not mandatory until January 1, 2010 and then only for applications received on or after January 1, 2010. Lenders may, at their option, start using the new GFE prior to January 1st; however once the new form is used, lenders must abide by the tolerance levels and also use the new HUD settlement statement. If a GFE is issued on the old form prior to January 1, 2010, then the old HUD-1 form must be used even if closing will occur after January 1, 2010. For GFEs issued on the old form, the loan originator has the option to reissue the GFE (with the same terms and charges) on the new form, in which case the settlement agent must complete the new HUD-1 form. Ronette Schlatter is Senior Compliance Coordinator for the Iowa Bankers Association. To remove yourself from this mailing list, click here. |
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