April 20, 2004
Robert E. Feldman,
Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
RE: EGRPRA Burden Reduction Comments
Fax (202) 898-3838
comments@fdic.gov
Dear Robert:
Thank you for providing us with the opportunity to comment on the request related
to Burden Reduction Recommendations for Consumer Protection Lending-Related
Rules as published in the Federal Register on January 21, 2004.
Our institution is a $28+ billion-dollar bank holding company with banking
offices located in Arizona, California, Colorado, Idaho, Nevada, New Mexico,
Utah and Washington. Our affiliated banks engage in financial activities that
are directly affected by lending-related consumer protection rules that may
be changed as a result of this comment request.
We appreciate the efforts the agencies are taking to reduce regulatory burden
and we wish to provide comments as follows:
HMDA
1. Government Monitoring Information - Ethnicity and Race -Lenders are required
to request information about an applicant's ethnicity, (e.g. Hispanic/Latino)
and race (American Indian/Alaska Native, Asian, Black/African American, Native
Hawaiian/Other Pacific Islander, or White). These Ethnicity and Race categories
were established to mirror definitions established by the Office of Management
and Budget, but are often confusing to applicants who insist their ethnicity
is actually a race. For example, many Hispanic applicants insist their race
is "Hispanic", even though that choice is not an option. As a result,
many applicants choose to not provide the information in telephone or internet
applications, and loan officers must "guess" when taking face-to-face
applications. Neither situation provides meaningful data.
We suggest that the OMB revisit the definitions, consider eliminating the Ethnicity
category, and reinstate Hispanic/Latino as a race category.
2. Refinance Definition - Lenders are required to report, as a refinance, all
loans secured by a dwelling replaced by another dwelling secured loan.
As a result of this broad definition, business purpose loans that meet the
definition of a refinance are HMDA reportable even when the stated purpose
of the loan does not involve a dwelling (such as a loan request to purchase
equipment for a business). We believe that the requirement to report these
transactions is contrary to the intent of HMDA.
We suggest that business loans that do not meet the HMDA purpose test be exempted
from HMDA reporting requirements.
3. Home Improvement Definition - Lenders are required to report an application
as Home Improvement if any portion of the refinanced loan is used for improvements.
In the Mortgage area, most refinance transactions are primarily a refinance
of a purchase money loan. The cash out that is used for home improvements is
not the primary portion of the loan.
We suggest that a loan should be reported as a home improvement loan only if
home improvement is the primary purpose of the loan.
4. Rate Spread Reporting - First lien one-time close construction-permanent
loans must include the calculation of the rate spread if the spread is equal
to or exceeds 3 percentage points. Regulation Z allows this type of loan to
be disclosed as separate transactions, one for the construction loan phase
and one for the permanent loan phase. Regulation Z also allows the points and
fees to be distributed between the two disclosures and further allows a lender
to assign all of the points and fees to either disclosure.
If a lender assigns all of the points and fees to the permanent loan phase,
the APR often exceeds the 3% threshold and the rate spread must then be reported.
The reporting of a rate spread on a one-time close construction-permanent loan
disclosed as outlined opens the lender up for unnecessary regulatory scrutiny,
public criticism and potential charges of predatory lending.
An exception should be added to the HMDA rate spread reporting requirements
to eliminate the reporting of a rate spread on a one-time close construction-permanent
loan when the APR on the permanent loan phase was calculated by including fees
and points for the construction phase.
5. Data Integrity - The various regulatory agencies use data integrity standards
that impose a significant burden on lenders that may not be justified. Although
we understand the importance of accurate data, we believe the current line
error standard of 5% is burdensome and expensive to maintain. HMDA reporting
now requires the reporting of up to 25 fields of data for each loan application.
If only one of the 25 fields is incorrect, the whole line is considered in
error for purposes of the 5% line error standard. A lender that reports 3,000
applications on their LAR that includes 75,000 fields of data, reaches the
5% standard if there is just one error on each of 150 of the 3,000 applications
reported.
When determining whether or not a lender's LAR meets accuracy requirements,
we recommend that the line error standard be eliminated, that an accuracy standard
of 5% per applied to key column errors, and that an accuracy standard of 1%
be applied to total data elements.
Regulation B,
Regulation Z and the Real Estate Settlement Procedures Act (RESPA)
- Application Disclosure Requirements
1. Adjustable Rate Mortgage (ARM), Home Equity Credit Line (HECL) and Servicing
Transfer (STD) Disclosure Requirements - Lenders are required to provide ARM
and HECL disclosures at the time an application is provided to a consumer.
Lenders are also required to provide an STD at the time of a face-to-face interview.
These requirements are inconsistent with other requirements that allow lenders
three business days to provide required disclosures (such as the Good Faith
Estimate and the initial Truth in Lending disclosure). As a result of these
inconsistencies, lenders often must maintain two sets of procedures to ensure
compliance with initial disclosure requirements. This is burdensome and expensive.
We suggest that the provisions of these sections be amended to allow a choice
in providing application-related disclosures - provide either at the time of
application or within three business days of receipt of an application.
2. Application Disclosure Requirements - Application disclosures should be
simplified and revised to make annual updates unnecessary. For lenders with
several programs, updating and distributing disclosures is time consuming and
expensive.
We suggest the following:
• Remove the requirement for a 15-year history on HECL disclosures.
• Establish a sample "payment" disclosure that would incorporate
minimum and maximum payments on a representative ARM loan or HECL based on the
minimum and maximum rates.
• Review other specific terms of the HECL disclosure requirements to identify
any requirements that can be summarized or shortened in order to provide a simpler,
easier to read, and more meaningful disclosure.
3. Servicing Transfer Disclosure Statement - While we agree that the servicing
transfer disclosure statement may be necessary for residential real estate
loans for which servicing may be transferred multiple times, it is an unnecessary
disclosure burden for consumer loans secured by residential real estate. Many
lenders that originate such products do not sell servicing on these loan types
and do not intend to do so.
We suggest that consumer loans secured by residential real estate be exempted
from the requirement to provide a STD if the lender can show that they service
these loans and do not sell them. The exemption would not be available if the
lender changed its policy and began to sell consumer loan servicing rights.
For covered loans, we suggest that the disclosure requirements be reviewed
to identify any terms that can be summarized or shortened in order to provide
a simpler disclosure and to make annual updates unnecessary.
4. Initial ARM Disclosure - Exception for Denied Applications - Unlike other
application disclosures, there is no stated exception for ARM disclosures and
brochures when an application is denied within three business days.
We suggest that this exception be incorporated into the Regulation or Commentary.
In addition, we suggest that the exception be expanded for all application
disclosures when applications have been withdrawn (or a conditional offer of
credit not accepted) by applicants within three business days.
5. Initial ARM Disclosure and HECL Disclosure - ARM disclosures are required
when an applicant's principal dwelling will secure a loan; HECL disclosures
are required when any dwelling owned by an applicant will secure a loan.
The HECL disclosure requirement outlined in Regulation Z (and explained further
in the Commentary) is inconsistent with Section 127A of the Truth in Lending
Act. Section 127A specifically refers to open-end consumer credit plans secured
by a consumer's principal dwelling.
We suggest that Regulation Z and its commentary be amended to require initial
HECL disclosures only when an applicant's principal dwelling will secure a
loan.
6. Notice of Right to Receive Appraisal - Lenders are provided two options
for providing appraisals to consumers: either routinely provide the appraisals,
or provide applicants with a notice of their right to receive a copy of the
appraisal. For lenders that elect to provide appraisals upon request, the required
notice must be in a form that the consumer can keep.
There is no stated exception to the requirement to provide an appraisal notice
when a loan application is denied prior to an appraisal being obtained on the
property. Providing such a notice serves no purpose other than to potentially
lead applicants to the erroneous belief that an appraisal was obtained.
The regulation or commentary should be expanded to include a specific exception
from appraisal notice requirements when a loan application is denied or withdrawn
within three business days and no appraisal has been completed.
We also recommend that an exception be made for business purpose loans where
the lender obtains a lien on a dwelling out of an "abundance of caution" and
no appraisal has been completed.
7. Good Faith Estimate and HUD-1/HUD-1A Settlement Statements - Many lenders
offer "fee free" loan products to consumers, whereby all third party
fees are paid by the lender. Providing a Good Faith Estimate (and a HUD-1A
Settlement Statement), reflecting the charges the applicant does not have to
pay, is an unnecessary requirement that increases costs and serves no useful
purpose.
We suggest that fees absorbed by the lender on "fee free" and "no
cost" consumer loans be exempted from disclosure on the Good Faith Estimate
and HUD-1/A Settlement Statement.
8. Good Faith Estimate - Format and Content - In its response to questions
from the Massachusetts Bankers Association, HUD opined that charges for any
required item previously obtained by a borrower must be listed as a "POC" on
the Good Faith Estimate. We believe that HUD's opinion is incorrect and is
inconsistent with 24 CFR 3500.7(a), which requires a good faith estimate of
charges the borrower is likely to incur in connection with the settlement.
Costs incurred prior to requesting a loan (e.g. appraisals and/or insurance
premiums) are not charges incurred in connection with the loan settlement.
Researching these costs to disclose them is an unnecessary exercise that does
nothing to meet the intent of RESPA, which is to provide a borrower with information
on the cost of obtaining a specific loan.
We recommend that HUD reverse its opinion on this and other issues relating
to previously obtained and gratuitous services.
9. Good Faith Estimate - Format and Content - Lenders are required to disclose
all charges the borrower is likely to incur in connection with the settlement
of a loan. Included in that disclosure is the estimated cost of hazard insurance
premiums. Given that many factors, including the applicant's credit score,
can cause significant variances in premiums for two similarly valued homes,
we suggest inclusion of a standardized statement such as "this estimate
does not include premiums for hazard insurance that will be required as a condition
of your loan. You should consult your insurance agent to obtain a quote."
10. Good Faith
Estimate -Required Service Providers - Lenders are required to
identify service providers and the nature of any business relationship.
This disclosure is unnecessary and provides little, if any, benefit to the
consumer. Typically, the service providers are entities with which the consumer
would have no contact in connection with the loan, such as credit reporting
agencies or flood determination companies, where the lenders obtain those services
directly.
We suggest that the Required Service Provider disclosure requirement be rescinded.
11. Affiliated Business Arrangement Disclosure - Lenders are allowed to refer
consumers to an affiliated entity for settlement services provided an Affiliated
Business Arrangement Disclosure is provided on a separate piece of paper.
We suggest these requirements be amended to remove the separate piece of paper
requirement. The disclosure should be allowed to be included on an existing
disclosure, so long as it is no less conspicuous than other information on
the disclosure and it is clearly visible to the consumer (such as bold face
type, enclosed in a text box, etc.).
12. Electronically Provided Disclosures - Unlike the Federal Reserve, the Department
of Housing and Urban Development (HUD) has not incorporated provisions for
lenders to provide electronic disclosures to applicants.
We suggest that (HUD) incorporate provisions and parameters to enable lenders
to provide electronic disclosures to applicants.
Regulation B
1. Collection of Monitoring Information - The monitoring information collection
rules under Regulation B should be amended to conform to the monitoring
information collection rules under Regulation C.
Regulation Z
1. Right to Rescind - Regulation Z provides consumers with a right of rescission
in certain transactions secured by a consumer's principal dwelling. The
required delay in disbursing funds serves little purpose for borrowers
who initiate such transactions.
The vast majority of consumers do not rescind transactions within three business
days of settlement; rather, the attempt seems to be made by borrowers whose
loans are in default, when their attorneys often correspond with lenders in
an attempt to exercise a three-year rescission in order to avoid foreclosure.
Alternatively, savvy borrowers who have paid fees in connection with a loan
know that they may not be entitled to receive a refund of those fees if they
cancel a transaction before settlement. Rather, they wait until after settlement
to rescind, leaving the lender responsible for paying settlement charges that
might not have been incurred had the borrower cancelled in a more timely manner.
We recommend that rescission rules be relaxed for transactions initiated by
consumers when a minimum number of days have elapsed between receipt of an
application and the settlement date, and the consumers have been given the
right to cancel a transaction within that time frame. A notice could accompany
other application disclosures, such as the good faith estimate or HECL application
disclosure, outlining the applicant's right to cancel a transaction within
(number to be determined) days of application. Fees for 3rd party services
already performed, such as appraisal, credit report, flood determinations,
etc., should not be refundable.
In the alternative, consumers could be provided with an option to elect to
waive their right to rescind. Consumers get very angry if they cannot have
their funds immediately and proving a bona fide financial emergency is too
subjective. Our only recourse is to allow a consumer to take out a side loan
for 30 days, which proves to be costly to the consumer and risky for the lender.
2. Effects of Rescission - When a consumer rescinds a transaction, a creditor
must refund all monies paid (even to third parties) by the borrower in connection
with the transaction.
While not specifically discussed in the regulation, the intent is for lenders
to reimburse consumers for "nonrefundable" costs such as credit and
title reports, and lender ordered services such as title insurance (on which
the lender can subsequently obtain a refund). We further believe that the regulation
never intended for lenders to reimburse consumers for refundable services that
they (consumers) obtained (such as property and flood insurance) in connection
with a loan and can obtain refunds themselves. Not excluding certain fees results
in consumers enjoying additional coverage paid by the lender or receiving a
double refund of premiums when they cancel or reduce insurance coverage.
We recommend that the commentary be expanded to exclude insurance premiums
paid by the borrower from the requirement. Borrowers have the ability to cancel
or reduce such coverage and receive a refund.
3. Owner-Occupied Rental Property - A loan to acquire owner-occupied rental
property
is considered business purpose if the property contains more than two housing
units.
A loan to improve or maintain owner-occupied rental property must contain more
than four housing units to be considered business purpose. The commentary should
be revised to provide a consistent definition of owner-occupied rental property,
regardless of the purpose.
4. Exemption for Certain Advertisement - Inconsistencies exist between advertisements
for credit products under Regulation Z and deposit products under Regulation
DD. Having different rules for different products increases the potential for
errors and omissions in advertisements, resulting in expensive rewrites and
wasted time.
Regulation Z should be amended to include exemptions similar to those outlined
in Regulation DD.
5. Triggering Terms and Required Disclosures (Closed-end Credit) - When advertising
closed-end credit products, triggering terms include number of payments (or
period of repayment), the amount of a finance charge, amount of payments, etc.
When triggering terms are set forth in an advertisement, the advertisement
must include the amount or percentage of down payment (on a credit sale), repayment
terms, and the APR.
a. Some information in an advertisement can be misleading and additional disclosures
are warranted. However, we do not feel that advertising the term of a loan
misleads consumers. When advertising long term mortgage loan products, it is
not practical to require additional disclosures. Market rates on such products
change daily (sometimes more frequently) and APRs may be based other factors
(such as private mortgage insurance, risk rating based on credit history, etc.)
thereby making accurate disclosures impossible.
b. There in little value to the consumer in requiring the disclosure of repayment
terms in an advertisement. The disclosures are not often very conspicuous,
and the consumer can easily overlook the information.
The number of payments or period of repayment should be removed as a triggering
term and the repayment terms be removed as a required disclosure.
6. Triggering Terms and Required Disclosures (Open-end Credit) - Some of the
additional disclosure requirements for open-end credit products do not provide
any value to the consumer and the volume of information that is required results
in footnotes that detract from the initial intent of the advertisement.
Disclosure requirements should be simplified to include as applicable:
a. The APR (if variable, the effective date and the fact that it is variable)
b. A statement that certain fees will apply to open and maintain an account,
a balloon payment will occur on home equity lines of credit (if a monthly payment
is disclosed) and to ask for additional information
c. If an advertisement states an initial rate that is not based on an index
and margin: the length of time the initial rate will apply, a reasonably current
APR, and the effective date of the APR
d. A customer should contact a tax advisor regarding the deductibility of interest
(if "tax deductible" is disclosed in an ad)
7. Advertising Requirements for Home Equity Lines of Credit - Amend the advertising
requirements to mirror those for closed-end loans. The advertising requirements
for home equity loans are concise. The preliminary disclosures provided contain
more detail and satisfy requirements for assisting consumers to shop for credit.
Quite often our advertisements are so "disclosure" heavy that we
have difficulty in our radio ads, not to mention the mouse print we have to
use for print ads.
8. Use of Annual
Percentage Rates in Oral Disclosures - When quoting interest rates
in response to a consumer's inquiry, lenders are required to state
only the APR, although the simple interest rate may also be stated.
The purpose of the disclosure requirement is to enable consumers
to "credit shop" and apply for the most favorable rate.
However, in an environment where the pricing of consumer loans
is based on risk factors such as credit score, consumers are increasingly
learning that they cannot obtain quotes until they apply for credit.
We believe it is not meaningful to consumers to disclose APRs in oral rate
inquiries. We further believe that consumers are interested in the rate that
will be charged, as evidenced by the frustration that loan officers experience
in trying to explain to consumers why APRs are higher than note rates. We believe
that providing a range of interest rates and the fees associated with such
loans would provide better information to consumers while rate shopping.
9. Advertising
Rules - Advertising rules under both open-end and closed-end should
be amended to include a mailing consisting of several separate
flyers or pieces of promotional material in a single envelope as
a single multiple-page advertisement under sections 226.16(c) and
226.24(d). To have to duplicate disclosure on every piece of paper
included in a mailing is unnecessary.
10. Clarification of Finance Charges - The commentary should be clarified to
provide a standard listing of fees that are always considered finance charges.
Many investors in the secondary market require that a settlement/closing fee
be included in the calculation of the finance charge and refuse to purchase
loans that do not meet this requirement. There is a specific exception outlined
in the commentary to 226.4(c)(7)2 that states that this fee is not a finance
charge (provided the specified circumstances are met) - yet they refuse to
accept this exception.
The same situation exists with document review fees which are also specifically
exempted under the commentary to 226.4(c)(7)1 - some investors refuse to purchase
a loan that contains a document review fee unless the fee has been included
in the finance charge.
Another fee that is subject to interpretation is the fee charged by an appraiser
to do a recertification of value after the completion of construction for a
one-time close construction and permanent loan. Although both of these loans
close at the same time, the permanent financing is contingent upon the completion
of construction. Therefore it can be argued that the recertification fee is
tied to the initial credit decision and is not a fee that is incurred during
the term of the loan. Specific guidance is needed concerning whether or not
this type of fee meets the test for exclusion under 226.4(c)(7)3 as a fee imposed
in connection with the initial decision to grant credit.
11. Credit Card
Provisions - Credit card provisions under 226.12(a) ad 226.12 (b)(5)
regarding business credit should be removed. Regulation Z is a
consumer protection law and this single piece of the regulation
is confusing and unnecessary.
Flood
1. Reliance on previous flood determinations - Regulations implementing the
Flood Disaster Protection Act require lenders to use the Standard Flood Hazard
Determination (SFHD) when making, increasing, renewing or extending loans secured
by improved property. In the book Mandatory Purchase of Flood Insurance Guidelines
published by FEMA, a flood determination can be reused for increasing, extending,
renewing or purchasing existing loans if certain conditions exist, i.e. determination
is less than seven years old, no change in the flood map, initially recorded
on a SFHD form.
Lenders often obtain "life of loan" coverage from flood determination
vendors when making the initial determinations in connection with improved
real estate loans. The purpose of life of loan coverage is for vendors to notify
lenders whenever changes in flood maps result in changes in the flood status
of loans within their portfolios. Absent notification, lenders could reasonably
rely on the fact that no change to flood status has occurred when renewing,
increasing, or extending loans. As such, we believe that no action should be
required by lenders when extending, renewing, or increasing a loan for which
life of loan coverage has been obtained, regardless of the age of the determination
or whether flood maps had changed.
We recommend that the ability to rely on previous flood determinations be expanded
to include initial determinations with life-of-loan coverage (if the initial
determination was recorded on a SFHD). Additionally, we request reliance on
previous flood determinations be made part of the regulation.
2. Loan Extensions - Lenders may extend loan payment due dates as an accommodation
to a borrower or offer holiday promotions to extend December or January payments
for borrowers who have remained current on their loans during the previous
year. Extending a loan payment results in the extension of the maturity date
of a loan by one month.
There is no definition of "extending" within the regulation, and
there is little guidance on what constitutes an extension. We feel that one-month
extensions, although they defer the maturity date of a loan, do not fall under
the intent of FEMA's regulations.
We suggest that an exception for short term extensions (such as those under
six months) be added to the regulation.
3. Junior Lienholders - Remove the requirement that junior lienholders are
responsible for ensuring coverage on all outstanding liens by allowing enough
coverage to protect the lender in junior position against risk. We have had
situations where the 1st lienholder disagrees that the property is in a flood
zone and does not require coverage; our vendor issued a flood certification
showing the property is in a standard flood hazard area. The consumer is forced
to either obtain insurance for both liens to satisfy our flood requirement
or not get the loan. This is also an issue when the first lienholder is not
subject to flood rules - such as finance companies and privately held first
mortgagees since neither of these lenders are subject to flood insurance requirements.
Privacy
1. Annual Privacy Notice - Lenders are required to send annual notices of their
privacy policy to consumers. This is in addition to the notice provided at
the time a relationship commences.
The annual notice requirement is costly, a waste of resources, and an unnecessary
burden to lenders (and other financial service providers). Consumers are deluged
with annual privacy notices from multiple financial services companies and
we suspect that most go unread. Despite attempts to simplify privacy notices,
they continue to be lengthy, overly detailed, and serve little purpose for
consumers.
The annual notice requirement should be eliminated. Instead, institutions should
be required to send privacy notice updates only when there are significant
changes to their privacy policies. The notices should be required to clearly
and conspicuously state the old and new terms of the policy and reiterate to
consumers how to opt out of information sharing.
Debt Cancellation
1. Oral Disclosures - When soliciting debt cancellation products in connection
with a loan, National banks are required to provide a detailed oral disclosure,
followed up (or accompanied by, in a face-to-face solicitation) with a
detailed written disclosure. The oral disclosure requirements include the
following statements:
o The fact that the consumer's purchase is optional;
o The fact that whether or not the consumer purchases debt cancellation will
not affect the application for credit or the terms of any existing agreement
the consumer has with the bank;
o The fact that the bank will give the consumer additional information before
the consumer is required to pay for debt cancellation;
o The fact that there are eligibility requirements, conditions and exclusions
that could prevent the consumer from receiving benefits under debt cancellation;
and
o The fact that the consumer should carefully read the contract for a full
explanation of terms of the debt cancellation.
The oral disclosure is too lengthy, duplicates much of the information in the
written disclosure, and provides little benefit to a consumer. We believe that
disclosing the fact that debt cancellation is optional, the cost of the debt
cancellation (currently not a requirement in an oral disclosure), and the fact
that additional disclosures will be provided contains sufficient information
for an initial solicitation.
Oral disclosure requirements under OCC regulations should be revised to provide
a shorter, more concise statement, followed up with a detailed written disclosure.
Homeownership
Counseling Notice
1. Notification upon delinquency - Lenders are required to provide notification
to a homeowner when a loan secured by the homeowner's principal (1-4 family)
dwelling becomes delinquent up to 45 days. Because the requirement to provide
the notice is not dependent upon the purpose of the loan, there is no stated
exception for commercial purpose loans. We have interpreted the regulation
to cover all past due loans where a homeowner's primary dwelling secures a
loan, even if the homeowner and the borrower are different persons.
In business and commercial lending, lenders may take a security interest in
a primary dwelling to strengthen the credit out of an abundance of caution.
Overall, the dwelling makes up a small portion of the collateral, most of which
may be comprised of business assets, and the existence of a dwelling as collateral
might not be identifiable in automated loan tracking systems. As such, covered
loans must be manually identified in order to comply with the notification
requirements, or the notice must be sent to all delinquent commercial borrowers.
The regulation should be revised to provide clarification regarding covered
loan types. We further suggest that business purpose loans should be exempted
from the notification requirements.
FACT Act
1. Credit Score Disclosure - Under the FACT Act, lenders will be required to
provide disclosures to consumers relating to credit scores for applications
of certain loan types. This requirement mirrors the requirements set forth
in statutes enacted by the State of California.
While we do not oppose the requirement to provide the disclosure, we have received
complaints from current California residents about the disclosure's content.
Due to the wording in the credit score disclosure, applicants think that their
application for credit has been denied. As a result, employees have been required
to explain to worried consumers that the disclosures are merely informational
and are not communicating a credit decision.
New regulations implementing this section of the FACT Act and the model disclosure
should be drafted in a manner that clearly communicates to consumers that the
disclosure is for informational purposes only and not a communication of a
credit decision. The disclosure should explain that factors contributing to
a credit score may appear negative but contribute to the score and do not necessarily
mean an application has been denied.
Again, thank
you for providing us with an opportunity to comment on ways to
reduce regulatory burden. If you have any questions concerning
our comments, please contact Kathy Gately, VP at 702-657-3528.
Sincerely,
Estella A. Tibbs
Vice President Compliance Manager
Nevada State Bank
Las Vegas, Nevada 89109
Member FDIC
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