realtors® association of new mexico resources/2012/legal_update_9_14_1… · • fha and condos...

REALTORS® ASSOCIATION OF

NEW MEXICO Legal Update

Presented By: Ashley Strauss-Martin, Esq. September, 2012

TOPICS COVERED TODAY • CFPB PROPOSED REGULATIONS

– QM AND QRM – NEW TILA/RESPA DISCLOSURES – LOAN ORIGINATORS

• FEDERAL RESERVE – BASEL III (PRONOUNCED BAA-zuhl )

• FHA AND CONDOS • THE 3.8% TAX • FHFA SHORT-SALE GUIDELINES • NEW MEXICO CASE LAW

CFPB PROPOSED REGULATIONS

• QUALIFIED MORTGAGE (QM) – QM – RULE WOULD SET STANDARDS FOR

LENDERS TO ENSURE THEY ONLY MAKE LOANS TO BORROWERS WHO HAVE THE ABILITY TO REPAY THEM

– APPLIES TO ALL MORTGAGE LOANS – CONCERN: WRITTEN TOO NARROWLY AND

LENDERS WILL ONLY MAKE LOAN WITHIN TIGHTLY SPECIFIED PARAMETERS, CLOSING DOOR FOR 1ST TIME BUYERS UNLESS THEY USE FHA WHICH PUTS MORE PRESSURE ON FHA


• QUALIFIED RESIDENTIAL MORTGAGE (QRM) – RULE WOULD SET MINIMAL UNDERWRITING

STANDARDS FOR LOANS THAT ARE PACKAGED INTO SECURITIES AN SOLD TO INVESTORS

– APPLIES ONLY TO SECURITIZED LOANS, DOES NOT APPLY TO FANNIE MAE AND FREDDIE MAC (UNTIL OUT OF RECEIVERSHIP)

– CONCERN: IF RULE REQUIRES A MINIMUM DOWN PAYMENT, SUCH AS 20%, MANY FIRST-TIME BUYERS WON’T QUALIFY

ANOTHER IMPORTANT FACTOR

• The Basel Committee on Banking Supervision provides a forum for regular cooperation on banking supervisory matters. Its objective is to enhance understanding of key supervisory issues and improve the quality of banking supervision worldwide. They meet in Basel, Switzerland.

• The Committee's members come from: – Argentina, Australia, Belgium, Brazil, Canada, China,

France, Germany, Hong Kong SAR, India, Indonesia, Italy, Japan, Korea, Luxembourg, Mexico, the Netherlands, Russia, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States


• BASEL III

– INTERNATIONAL BANKING STANDARDS BEING WRITTEN THAT WOULD INCLUDE REQUIREMENTS ON HOW MUCH CAPITAL BANKS MUST HOLD ON THEIR BOOKS BASED ON THE TYPE OF LOANS THEY MAKE


• BASEL III – PREVIOUS “ VERSIONS” ONLY APPLIED

TO THE LARGEST BANKS, BUT ASPECTS OF BASEL III COULD APPLY TO REGIONAL AND COMMUNITY BANKS

– COUNTRIES MUST CHOSE TO ADOPT AND ENFORCE – PROPOSAL: “ADOPT”

– EVEN IF DON’T ADOPT, MAY NEED TO ABIDE IF THEY DO BUSINESS IN COUNTRIES THAT HAVE ADOPTED THEM


• BASEL III – CONCERN: REQUIREMENTS THAT

WOULD FORCE BANKS TO HOLD MORE CAPITAL FOR ALL BUT THE

MOST CONSERVATIVE LOANS - FEDERAL RESERVE – SUPPORTS - FDIC BOARD MEMBER (HOENIG) HAS SPOKEN AGAINST IT


• TILA/RESPA DISCLOSURES – For more than 30 years, 2 different disclosure

forms to consumers applying for a mortgage – Developed by 2 different federal agencies

under 2 federal statutes: the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act of 1974 (RESPA)

– The information is overlapping and language inconsistent. Consumers found confusing.

TILA/RESPA DISCLOSURES

– Dodd-Frank Wall Street Reform and

Consumer Protection Act directs the CFPB to combine the forms.

– 1st new form -the Loan Estimate- is designed to provide disclosures that will be help consumers understand key features, costs, and risks of mortgage


– The 2nd form - the Closing Disclosure - provides disclosures that will helpful consumers understand all of the costs of the transaction.


– Forms use clear language; designed to make

it easier to locate key information • interest rate • monthly payments • costs to close the loan

– Forms provide more information to help consumers decide

• whether they can afford the loan • to compare the cost of different loan offers,

including the cost of the loans over time


• New forms

– reconcile the differences between the existing forms and

– combine several other mandated disclosures.

• CFPB has provided detailed instructions on how to complete the new forms; reducing burden on lenders and others in preparing forms in the future.

TILA/RESPA DISCLOSURES • Applies to most closed-end consumer

mortgages. • Does not apply to:

– home-equity lines of credit – reverse mortgages – mortgages secured by a mobile home or by a

dwelling that is not attached to real property • Does not apply to loans made by a

creditor who makes 5 or less mortgages/yr

TILA/RESPA DISCLOSURES • LOAN ESTIMATE

– Replaces 2 current Federal forms: Good Faith Estimate designed by the HUD under RESPA and the “early” Truth in Lending disclosure designed by the Federal Reserve System under TILA. It also incorporates new disclosures required under Dodd-Frank Act.

– The lender may rely on a mortgage broker to provide the Loan Estimate form. However, the lender also remains responsible for the accuracy of the form.

TILA/RESPA DISCLOSURES • LOAN ESTIMATE FORM

– Timing: lender or broker must give within 3 business days after the consumer applies for a mortgage loan. Rule contains definition of an “application”.

– Limitation on fees: lender generally cannot charge consumers any fees until consumer has been given the LE form and the consumer has communicated his/her intent to proceed. Exception: credit reports.

– Disclaimer on early estimates. Lenders/brokers may provide consumers with written estimates prior to application. Estimates must contain a disclaimer to prevent confusion with the LE form. Disclaimer not required for advertisements.


• CLOSING DISCLOSURE

– Replace the current HUD-1 and the revised Truth in Lending disclosure

– Contains additional new disclosures required by the Dodd-Frank Act and a detailed accounting of the settlement transaction.

TILA/RESPA DISCLOSURES • Timing: must be given at least 3 business days

before the consumer closing. • If changes occur between the time the form is

given and the closing, the consumer must be provided a new form. Then, the consumer must be given 3 additional business days to review that form before closing.

• Exception: negotiations between buyer/seller after the final walk-through, minor changes (less than $100 in increased costs) .

TILA/RESPA DISCLOSURES • Provision. Currently, settlement agents required

to provide HUD-1; lenders required to provide revised Truth in Lending disclosure.

• CFPB proposes 2 alternatives for who is required to provide consumers with the new Closing Disclosure form. – #1: lender would be responsible for delivering the

Closing Disclosure form to the consumer – #2: lender may rely on the settlement agent to

provide the form. However, lender would remain responsible for the accuracy of the form


• Limits on Closing Cost Increases – Rule restricts the circumstances in which

consumers can be required to pay more for settlement services (i.e, appraisals, inspections, etc) than the amount stated on their LE form, unless exception applies.

TILA/RESPA DISCLOSURES • CHARGES THAT CAN’T INCREASE AT

CLOSING: – lender's/mortgage broker's charges for its own

services; – charges for services provided by an affiliate of

the lender or mortgage broker; – charges for services for which the lender or

mortgage broker does not permit the consumer to shop

– unless exception applies, charges for other services could not increase by more than 10%

TILA/RESPA DISCLOSURES • CHARGES THAT CAN INCREASE AT

CLOSING - – Consumer asks for a change; – Consumer chooses a service provider that was not

identified by the lender; – Information provided at application was inaccurate or

becomes inaccurate; – Loan Estimate expires; – When an exception applies, the lender generally must

provide an updated Loan Estimate form within 3 business days.


• CHANGES TO APR

– Redefines the way APR is calculated. APR encompass almost all of the up-front costs of loan; making it easier for consumers to use APR to compare loans and easier for industry to calculate APR (NAR does not support)

•


• Changes in APR - Under the proposed test, a fee or charge is included in the finance charge if it is: – payable directly or indirectly by the consumer’

to whom credit is extended, and – imposed directly or indirectly by the creditor

as an incident to or a condition of the extension of credit.


• RECORDKEEPING – requires lenders to keep records of LE and

CD in a standard electronic format; making it easier to monitor compliance. Should smaller lenders should be exempt?


• EFFECTIVE DATE

– CFPB seeking comment on when this final rule should be effective. Because the final rule will provide important benefits to consumers, the Bureau seeks to make it effective as soon as possible. However, industry needs time.

LOAN ORIGINATORS • A creditor may offer a loan with or without

upfront fees. • If loan is offered with upfront fees, must:

– result in an interest rate reduction, and – creditor must make available to consumer "a

comparable, alternative loan with no upfront discount points, origination points, or fees that are retained by the creditor [or] broker"—a "zero-zero alternative."

LOAN ORIGINATORS • "Comparable alternative loan" : "that the two

loans for which quotes are provided must have: – the same terms and conditions, other than the interest

rate, – any terms that change solely as a result of the

change in the interest rate, and the amount of any discount points and origination points and fees."

• Does not apply if the creditor or broker makes a good faith determination that the consumer is unlikely to qualify for such a loan.

LOAN ORIGINATORS • B/C of potential for "manipulation of underwriting

standards" to prevent consumers from qualifying for such a loan, CFPB is considering safeguards to prohibit creditors from changing their qualification standards.

• CFPB proposed that creditors maintain records

"sufficient to evidence that creditor made available to consumer the comparable, alternative loan that does not include discount points and originator points or fees"—the "zero-zero alternative"—or if not available "a good faith determination that the consumer is unlikely to qualify for such a loan."

LOAN ORIGINATORS • Record retention time period requirements:

extended from 2 years to 3 (5?) and apply to all loan originators and not simply creditors.

• "loan originator organizations" are required to obtain a criminal background check and credit report for those loan originators who are not required to be licensed under the SAFE Act and who are not licensed. This has a regulatory impact on depository institutions, including credit unions, whose loan originators generally are not subject to state licensing.

LOAN ORIGINATORS • Proposed rule significantly changes definitions:

"loan originator" and "compensation," presents newly defined terms such as "loan originator organization" and "individual loan originator," and limits the exemptions for servicers.

• I.E., definition of "loan originator" under current law is consistent with the definition in Dodd-Frank, but CFPB plans to interpret several terms within the definition of "loan originator" broadly, and add "takes an application" and "offers" to the definition of "loan originator."

FHA CONDO APPROVAL • No More Spot Approval • Is seller’s condo approved?

– https://entp.hud.gov/idapp/html/condlook.cfm – Once approved, buyer can use any lender

• If not, 2 ways to get approved – HUD Review and Approval (HRAP) – go directly

through HUD — 4 - 6 weeks. – Direct Endorsement Lender Review and Approval

(DELRAP) – go through a direct endorsement lender who has authority to approve the condo. Say up to 30 days.

FHA CONDO APPROVAL • Steps for getting a condo complex

approved – http://portal.hud.gov/hudportal/documents/hud

doc?id=11-22mlguide.pdf • Cost

– Existing Condo Complex - $300 – New Condo Complex - $1,000, but developer

will typically cover

FHA EASES CONDO FINANCING

• Investors can buy up to 50% of units (was 10%) if at least half the units are conveyed to individual owners or are under contract as owner-occupied

• Allow more commercial space (50%, was $25%) • Board Certification –

– recognizes board reps rely on attorneys re: project’s compliance with state and local laws

– removes language where person signing certifies s/he has no knowledge of conditions that may cause mortgage to become delinquent

FHA EASES CONDO FINANCING

• HOA Dues – allows 15% of project to be 60days late (was, 30 days)

• Owner occupies remains 50%, but if unit is REO, the 50% rule is waived. NAR wants rule removed completely

• Remains: 30% of units in project pre-sold before FHA, spot approvals still not allowed

THE 3.8% TAX • INCLUDED IN THE HEALTH CARE BILL

THAT WAS PASSED IN 2010, EFFECTIVE JANUARY, 2013

• GOOD NEWS: WILL NOT AFFECT ALL REAL ESTATE TRANSACTIONS

• 3.8% TAX ON SOME INCOME INTEREST, DIVIDENDS, RENTS (LESS EXPENSES) AND CAPITAL GAINS (LESS CAPITAL LOSSES)

THE 3.8% TAX • AFFECTS

– INDIVIDUALS WITH AGI ABOVE ($200,000) AND COUPLES FILING A JOINT RETURN WITH AN AGI OF MORE THAN $250,000

– ONLY CAPITAL GAINS OVER $500,000 – FORMULA: NEW TAX APPLIES TO LESSER

OF: • INVESTMENT INCOME AMOUNT • EXCESS OF AGI OVER THE $200,000 OR

$250,000 AMOUNT

THE 3.8% TAX • EXAMPLES: (COUPLE – JOE AND KATY

SELL THEIR PRIMARY RESIDENCE) – AGI BEFORE TAXABLE GAIN $325,000 – GAIN ON SALE OF RESIDENCE $525,000 – TAXABLE GAIN (≥ $5000,000) $ 25,000 – NEW AGI $350,000 – EXCESS OF AGI OVER $250,000 $100,000 – LESSER AMOUNT (TAXABLE) $ 25,000 – TAX DUE (3.8% OF $25,000) $ 950

THE 3.8% TAX

• EXAMPLE: (KEN AND BARBIE SELL NON-REAL ESTATE ASSETS) – AGI BEFORE TAXABLE GAIN $140,000 – GAIN ON STOCKS/BONDS $120,000 – NEW AGI $260,000 – EXCESS OF AGI OVER $250,000 $ 10,000 – LESSER AMOUNT (TAXABLE) $ 10,000 – TAX DUE (3.8% OF $10,000) $ 380

THE 3.8% TAX

• EXAMPLE – TOM HAS A “DAY JOB” AND RENTAL INCOME – AGI BEFORE RENTS $ 85,000 – GROSS RENTS $130,000 – EXPENSES $110,000 – NET RENTS $ 20,000 – NEW AGI $105,000 – EXCESS OF AGI OVER $200,000 $ 0 – LESS AMOUNT (TAXABLE) $ 0 – TAX DUE (3.8% OF $0) $ 0

THE 3.8% TAX • EXAMPLE: MARY’S SOLE SOURCE OF INCOME IS

FROM OWNING AND OPERATING COMMERCIAL BUILDINGS – THIS IS TREATED AS BUSINESS INCOME, NOT INVESTMENT INCOME

• GROSS RENTS $750,000 – EXPENSES $520,000 – NET RENTS $230,000 – NEW AGI $230,000 – EXCESS OF AGI OVER $200,000 $ 30,000 – LESSER AMOUNT (TAXABLE) $ 0* – TAX DUE (3.8% of $30,000) $ 0 * SHE HAS NO INVESTMENT INCOME

TOP 10 THINGS TO KNOW ABOUT THE 3.8% TAX

• #1: When you add up all of your income from every possible source, and that total is less than $200,000 ($250,000 on a joint tax return), you will not be subject to this tax.

• #2. The 3.8% tax will never be collected as a transfer tax on real estate of any type, so you’ll never pay this tax at the time that you purchase a home or other investment property.


• #3. You’ll never pay this tax at settlement

when you sell your home or investment property. Any capital gain you realize at settlement is just one component of that year’s gross income.


• #4. If you sell your principal residence, you will still receive the full benefit of the $250,000 (single tax return)/$500,000 (married filing joint tax return) exclusion on the sale of that home. If your capital gain is greater than these amounts, then you will include any gain above these amounts as income on your Form 1040 tax return. Even then, if your total income (including this taxable portion of gain on your residence) is less than the $200,000/$250,000 amounts, you will not pay this tax. If your total income is more than these amounts, a formula will protect some portion of your investment.


• #5. The tax applies to other types of investment income, not just real estate. If your income is more than the $200,000/$250,000 amount, then the tax formula will be applied to capital gains, interest and dividend income and net rents

• #6. The tax goes into effect in 2013. If you have investment income in 2013, you won’t pay the 3.8% tax until you file your 2013 Form 1040 tax return in 2014. The 3.8% tax for any later year will be paid in the following calendar year when the tax returns are filed.


• #7. In any particular year, if you have no income from capital gains, rents, interest or dividends, you’ll never pay this tax, even if you have millions of dollars of other types of income.

• #8. The formula that determines the amount of 3.8% tax due will always protect $200,000 ($250,000/joint return) of your income from any burden of the 3.8% tax. i.e., if you are single and have a total of $201,000 income, the 3.8% tax would never be imposed on more than $1,000.


• #9. It’s true that investment income from rents on an investment property could be subject to the 3.8% tax. But: The only rental income that would be included in your gross income and possibly subject to the tax is net rental income: gross rents minus expenses like depreciation, interest, property tax, maintenance and utilities.


• #10. The tax was enacted along with the health care legislation in 2010. It was added to the package just hours before the final vote and without review. NAR strongly opposed the tax at the time, and remains hopeful that it will not go into effect. The tax will no doubt be debated during the upcoming tax reform debates in 2013.

THE 3.8% TAX

• http://speakingofrealestate.blogs.realtor.org/2010/11/24/the-3-8-tax-is-not-a-real-estate-transfer-tax/

• http://www.realtor.org/topics/health-care-reform/38-tax-faq

http://speakingofrealestate.blogs.realtor.org/2010/11/24/the-3-8-tax-is-not-a-real-estate-transfer-tax/



FEDERAL HOUSING FINANCE AUTHORITY (FHFA)

SHORT SALE GUIDELINES

• EFFECTIVE JUNE, 2012 – Servicers required to review and

respond to short sales within 30 days of receipt of short sale offer

– Must provide weekly status updates to borrower if offer is still under review after 30 days

FHFA SHORT SALE GUIDELINES

• Must make and communicate final decisions to the borrower within 60 days of receipt of short sale offer and complete borrower response package

• Borrowers will not be eligible for a new mortgage backed by Fannie Mae or Freddie Mac for at least 2 years after a short sale


• EFFECTIVE NOVEMBER 1, 2012 – CAN QUALIFY FOR SHORT SALE IF CURRENT ON

MORTGAGE IF HAVE ELIGIBLE HARDSHIP – EXPEDITED PROCESSING FOR HARDSHIPS W/O

ADD’L APPROVAL FROM FANNIE OR FREDDIE – EXAMPLES OF HARDSHIPS:

• DEATH OF BORROWER OR PRIMARY OR SECONDARY WAGE EARNER, UNEMPLOYMENT, DIVORCE, LONG-TERM DISABILITY, RELOCATION FOR A JOB (MORE THAN 50 MILES ONE WAY), INCREASED HOUSING EXPENSES, DISASTER (NATURAL OR MAN-MADE), BUSINESS FAILURE

–


• QUICKLY AND EASILY QUALIFY CERTAIN BORROWERS WHO ARE CURRENT ON THEIR MORTGAGE

• WAIVE RIGHT TO DEFICIENCY JUDGMENT FOR CONTRIBUTION WHEN BORROWER HAS SUFFICIENT INCOME OR ASSETS TO MAKE CASH CONTRIBUTIONS OR SIGN PROM NOTE


• SPECIAL TREATMENT FOR MILITARY PERSONNEL – IF BEING RELOCATED, AUTOMATICALLY ELIGIBLE FOR SHORT SALE AND DON’T NEED TO CONTRIBUTE IF THERE IS SHORT FALL

• CONSOLIDATE EXISTING SHORT-SALE PROGRAMS INTO A SINGLE UNIFORM PROGRAM


• PROVIDE SERVICERS AND BORROWERS CLARITY ON PROCESSING A SHORT SALE WHEN A FORECLOSURE SALE IS PENDING

• FREDDIE AND FANNIE WILL OFFER UP TO $6,000 TO SECOND LIEN HOLDERS TO EXPEDITE SHORT SALE

VIOLATIONS OF FHFA SHORT-SALE GUIDELINES

• Contact lender or servicer first. Try to settle the problem directly.

• If cannot solve the problem, contact servicer, and verify if the mortgage loan is owned or guaranteed by Fannie Mae or Freddie Mac.

• Or, verify at http://www.makinghomeaffordable.gov/get-assistance/loan-look-up/Pages/default.aspx.


If mortgage is not owned or guaranteed by Fannie Mae or Freddie Mac or a Federal Home Loan Bank, contact the lender or servicer’s primary regulator. FHFA has no regulatory authority, and will be unable to help. To identify the primary regulator, see http://www.helpwithmybank.gov/national-banks/national-banks.html.


• If the property or mortgage is owned or guaranteed by Fannie Mae or Freddie Mac, contact the Enterprise directly.

• Fannie Mae can be reached at 1.800.732.6643 or www.fanniemae.com. Freddie Mac can be reached at 1.800.373.3343 or www.freddiemac.com.


• If unsuccessful, Contact FHFA – Email at [email protected] – Fax at 202.649.107 – Call us at 202.649.3811 (9 -5 EST M-F) – Letter at:

• Consumer Communications • Federal Housing Finance Agency • Constitution Center • 400 7th Street, SW • Washington, DC 20024

mailto:[email protected]


• Provide the following information: – Name, address, telephone number(s) and

email address. – If different, borrower/s’ name, address,

telephone number (s) and email address. – Complete property address for the mortgage

or REO property. – Name of the lender or servicer involved in the

issue.


• Name of the regulated entity involved in issue; e.g., Fannie Mae, Freddie Mac or a Federal Home Loan Bank.

• Brief description of issue; specifically, what happened? Who was involved? What resolution do you/borrower seek?

• Name/s of other government agencies contacted about the issue.

• The borrower’s authorization for you to represent him/her, if you are not the borrower.


• Do not provide – Personal or confidential information such as

social security number, credit card or bank account numbers.

– Personal financial documents such as loan applications, mortgage statements, income verification, tax returns, etc.

NEW MEXICO CASE LAW • ELANE PHOTOGRAPHY LLC V.

VANESSA WILLOCK – FACTS: PHOTOGRAPHER WAS

CONTACTED BY CLIENT TO PHOTOGRAPH THE COMMITMENT CEREMONY OF VANESSA WILLOCK AND HER SAME-SEX PARTNER. PHOTOGRAPHER REFUSED. PLAINTIFF CLAIMED DISCRIMINATION BASED ON SEXUAL ORIENTATION.

NEW MEXICO CASE LAW • ELANE PHOTOGRAPHY LLC V.

VANESSA WILLOCK – New Mexico Human Rights Act prohibits any

person in any public accommodation to make a distinction, directly or indirectly, in offering or refusing to offer services...to any person [because of they are a member of a protected class]

NEW MEXICO CASE LAW

• ELANE PHOTOGRAPHY LLC V. VANESSA WILLOCK – Public accommodation: establishment that

provides or offers its services, facilities, accommodations or goods to the public, but does not include a bona fide private club or other place or establishment that is by its nature and use distinctly private.

NEW MEXICO CASE LAW • Elane Photography advertises on multiple

internet sites, its website, the Yellow Pages • Does not participate in selective advertising,

such as telephone solicitation or seek to target a select group of people

• NMHRA was meant to reflect modern commercial life and expand protection from discrimination to include most establishments that typically operate a business in the public commerce.

NEW MEXICO CASE LAW

• Elane Photography claimed freedom of expression under U.S. and N.M. constitutions – artistic skills and creative process used to create photographs constitutes artistic expression entitled to 1st Amendment protection.

• Court said mere fact that a business provides a good or service with a recognized expressive element does not allow the business to engage in discriminatory practices.

NEW MEXICO CASE LAW

• FREEDOM OF RELIGIOUS EXERCISE • ELANE PHOTOGRAPHY CLAIMED THAT ITS

RELIGIOUS BELIEFS PROHIBIT THEM FROM PHOTOGRAPHING IMAGES THAT CONVEY A MESSAGE THAT MARRIAGE CAN BE DEFINED OTHER THAN THE UNION OF ONE MAN AND ONE WOMEN. NOT DISCRIMINATION B/C WOULD HAVE PHOTOGRAPHED VANESSA IN OTHER CONTEXTS

NEW MEXICO CASE LAW • Court held that the NMHRA applies generally to

all citizens transacting commerce and business through public accommodations that deal with the public at large and any burden on religion or some religious beliefs is incidental and uniformly applied to all citizens; NMHRA is not directed at religious or particular practices, but is directed at persons engaged in commerce in New Mexico.

• NMHRA does not just apply to cases involving government agency as an adverse party.

RANM LEGAL HOT LINE

1-877-699-7266 [email protected]

MONDAY – FRIDAY

9:00 TO 1:00 PM

mailto:[email protected]

REALTORS ASSOCIATION

OF NEW MEXICO

LEGAL UPDATE SEPTEMBER, 2012

THANK YOU!

realtors® association of new mexico resources/2012/legal_update_9_14_1… · • fha and condos...

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