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Practical Advice During The
Residential Real Estate Crisis |
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It is difficult to pick up a
newspaper anywhere in the United States and not find an article
on the economy, the downturn in the residential real estate
market, and the prospect of the economy sliding into recession.
“U.S. Housing market is currently suffering one of the worst
downturns in history.” “The outlook is bleak with new home sales
projected to fall 13 percent in 2008...” No sector of the U.S.
economy is immune from the impact of the fall in the residential
real estate market. Particularly hard hit has been the
residential construction market.
As the slowdown in the housing market has starved builders of
needed operating cash, many large homebuilders from all corners
of the United States have shut their doors, slashed their
workforce, filed for bankruptcy protection, or at a minimum
slashed prices of their inventory. Since August 2006, many large
homebuilders from throughout the United States have succumbed to
the downturn and have filed for bankruptcy relief, including
such notables as Meyer-Sutton Homes, Inc. (GA), Neuman Homes
(IL), Levitt and Sons (FL), and Technical Olympic USA (Tousa),
Inc. (FL). In North Carolina, Den-Mark Construction, Inc. of
Youngsville, North Carolina filed for Chapter 11 protection in
April 2008. Others are likely to follow as market indicators and
economic prognosticators indicate there may be no end soon in
sight. The impact on homebuilders has created a trickle-down
effect on construction lenders, contractors, subcontractors, and
suppliers. A break in any link in the construction industry
chain creates a challenge to keep cash flowing throughout these
interconnected segments.
Practical Advice for Those Who Extend Credit
One pervasive impact of the real estate downturn is the
tightening credit markets. Buyers and builders are finding loan
approvals more difficult to obtain as lenders raise their credit
standards to protect against the perceived higher risk. The
resulting overall reduction in construction volume hurts
subcontractors and suppliers who have become dependent on the
previous cash flow levels of higher construction spending. For
those who extend credit to these sectors, the following offers
some practical advice to keep in mind, particularly during this
period of economic downturn.
• Maintain high credit standards. Now is not the time
to lessen your
standards for extending credit.
• Thoroughly document every transaction. Make sure all
contracts are
properly executed, legible and, if
possible, witnessed and/or notarized. If
collateral is involved, obtain the proofs
of delivery and acceptance. File
UCC-1 Financing Statements if you have a
security interest in your
customer’s assets.
• Take extra efforts to verify the customer’s income
and ability to repay the
debt. Ensuring that specific, adequate
procedures are in place (and
consistently applied) can save companies
tens of thousands of dollars in
write-offs no matter the economic climate.
• Periodically check your customers’ credit and trade
references.
• If collateral is involved, confirm its location, know
who is in possession,
and make periodic visual inspections to
determine its present condition
and value.
• Monitor even slight fluctuations in payments and
immediately act on
delinquencies.
• Understand your company’s collection procedures, and
be familiar with
your in-house and outside counsel.
Pre-Bankruptcy Protections
There are several steps that lenders, contractors,
subcontractors, and suppliers can take to protect their rights
when a customer defaults, provided that the customer has not
filed for bankruptcy relief. First, wherever possible, obtain
personal guarantees. Make sure the personal guaranty contains an
original, legible signature and, if possible, have the signature
witnessed and/or notarized. Also, check that the person signing
the personal guaranty signed in a personal capacity, not as an
officer of a corporation.
Second, if collateral is involved, have the contract provide for
possession upon default. Prior to a default, periodically
investigate the condition and location of the collateral. If a
default occurs, act quickly on recovering the collateral.
Develop and foster relationships with recovery vendors so if a
default occurs, you can act quickly to recover your collateral.
Third, consider reclaiming goods sold to an insolvent buyer.
Reclamation is a legal remedy allowing the seller to recover
(i.e., “reclaim”) goods that it sold to a buyer whom it
discovers is insolvent. The right of reclamation by the seller
upon discovery of a buyer’s insolvency is provided in Article 2
of Uniform Commercial Code, Section 2-702. The Uniform
Commercial Code allows the seller to reclaim its goods under
certain circumstances, but demand must be made within ten (10)
days after the buyer receives the goods. Generally speaking, a
buyer is insolvent if it has either ceased to pay its debts in
the ordinary course of its business, is unable to pay its debts
as they become due, or is insolvent within the meaning of
federal bankruptcy law (entity’s debts exceed the value of
assets at a fair evaluation).
Finally, attempt to secure payment of a debt through the use of
mechanics’ and materialmens’ liens. As a general rule, any
person who performs or furnishes labor or materials pursuant to
a contract with the owner of real property shall be entitled to
a lien on the real property to secure payment of all debts owed
for the labor or materials provided. Generally, contractors have
liens on land while subcontractors have liens on money that is
owed up the chain of contract. The purpose of lien statutes is
to protect the interests of the supplier in the materials it
supplies. The materialman, rather than the owner, should have
the benefit of the materials that go into the property and give
it value. The basic requirements for perfecting and enforcing
lien rights include timely filing a claim of lien in the clerk
or recorder’s office in the county in which the real property is
located. In North Carolina, a Claim of Lien on Real Property
must be filed within 120 days after the date of last furnishing
of labor or materials to the job site. In order to enforce a
claim of lien in North Carolina, the contractor must file suit
within 180 days of the last date of furnishing. The requirements
for establishing and enforcing lien rights are very detailed and
time sensitive. Failure to proceed within the statutory
requirements can quickly lead to the loss of liens rights and
you should consult with an attorney with knowledge in this area
of the law prior to proceeding.
Post-Bankruptcy Protections
All is not lost when a customer files bankruptcy. Once notified
that a customer has filed for bankruptcy protection, the best
business practice is to stop everything and contact your
attorney. Mechanic’s and materialmen’s liens and reclamation may
provide a way to protect your rights following a customer’s
bankruptcy.
Mechanic’s Liens and the Automatic Stay. Upon the filing
of the debtor’s bankruptcy petition, an “automatic stay” is
simultaneously put into effect that, for the most part,
precludes creditors from taking any actions against the debtor
without prior bankruptcy court approval. The automatic stay
stops creditors’ continued collection efforts, foreclosures, and
the continuation and commencement of any actions against the
debtor. The automatic stay prohibits any act to create, perfect,
or enforce liens against the property of the debtor’s estate.
The Bankruptcy Code broadly defines a lien and includes security
interests, statutory liens, and judicial liens, as well as
inchoate charges against property.
The Bankruptcy Code provides exceptions to the application of
the automatic stay, one of which is the filing of a claim of
lien. It is not a violation of the automatic stay to file a
claim of lien after the debtor filed its bankruptcy petition if
the lien rights relate back to a date prior to the bankruptcy.
In North Carolina, a claimant’s lien rights relate back to the
first date it furnished materials to the project. Generally, the
trustee appointed in the debtor’s bankruptcy may invalidate a
transfer of property that occurs after the commencement of the
bankruptcy case, and which is not authorized by the Bankruptcy
Code or the bankruptcy court. However, the trustee is prohibited
from invalidating the perfection of a mechanic’s and
materialman’s lien that by statute relates back to a time prior
to the debtor’s bankruptcy filing.
To the extent that a creditor wishes to proceed to perfect such
a lien claim by filing suit against the debtor, the creditor
must seek relief from the automatic stay. While it is not a
violation of the automatic stay to file the claim of lien after
the bankruptcy has been filed, a creditor must obtain relief
from the automatic stay in order to file a state court action
against the debtor to enforce and foreclose on the lien.
Reclamation. As noted above, reclamation is a legal
remedy allowing the seller to recover goods that it sold to a
buyer whom it discovers is insolvent. Reclamation is also
available after bankruptcy is filed. In October 2005, revisions
to the Bankruptcy Code expanded a seller’s right to reclaim
goods sold to an insolvent buyer. The seller may demand
reclamation of the goods that the debtor received within 45 days
before the debtor’s bankruptcy petition was filed. Demand must
be made in writing not later than 45 days after the debtor
received the goods. If this 45 day time period expires after the
date that the bankruptcy was filed, then the seller’s
reclamation demand must be made within 20 days of the date the
bankruptcy petition was filed. If the seller fails to make the
proper reclamation demand or is unable to recover the goods, the
revised Bankruptcy Code provides seller with an Administrative
Priority Claim for the value of the goods that debtor received
20 days before the bankruptcy filing if the goods were sold to
the debtor in the ordinary course of the debtor’s business. Such
administrative claims are paid before general unsecured claims,
improving the creditor’s collection position.
The above practical advice is relevant not only to those
impacted by the recent real estate market woes, but to anyone
who extends credit, especially during an economic downturn. We
encourage you to contact legal counsel when confronted with
situations involving liens, general collections or a customer’s
bankruptcy.
For additional information or questions on this topic contact
Thomas A. Gray at (919) 250-2121 or
tgray@smithdebnamlaw.com.
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A Simple Instrument For a Complex World
Here is the scenario: Mortgage
and other bill payments are due, investment or other financial
decisions need to be made and you are unable to carry out the
actions necessary to accomplish them due to an accident,
illness, or a prolonged absence. Your family wants to respond to
these needs, but doesn’t have the legal authority to do so. What
is the solution?
A simple, proven tool available to handle situations like this
is the Financial Power of Attorney (“FPA”). A FPA is a legally
binding document authorizing the person you select (your
“attorney-in-fact,” or “agent”) to make decisions for you with
respect to your assets, ensuring that your finances are managed
even if you are not able to do so.
A FPA can be done in anticipation of a future need, for a
special purpose, and for a limited time depending on your
situation and desires. In addition to providing peace of mind
for yourself, it can prove a great blessing for your family
should you ever become incapacitated and unable to make
decisions for yourself. Without a power of attorney in place,
your spouse, closest relatives, or companion will generally have
to ask a court for authority over at least some of your
financial affairs. The FPA empowers those you trust to act on
your behalf to prevent loss of assets due to non-payment or
inaction, to avoid the delay and expense of otherwise necessary
court proceedings, and generally manage your finances in
accordance with your instructions.
Creating a Financial Power of Attorney
Depending on your personal situation and the extent or limits on
authority given to your agent, the FPA can be basic or
customized to your specific intent and financial portfolio. In
addition to preparing a general FPA, some banks and brokerage
companies have their own specific preferred FPA forms. If you
want your agent to have an easy time with these institutions,
you may need to prepare two (or more) FPAs: your own form and
forms provided by the institutions with which you do business.
In order to make a FPA valid under North Carolina law you must
first ensure that the language used and specific powers granted
by you to your agent are proper. You must then sign the document
in front of a notary public, having demonstrated the competency
and capacity to do so. You may also be required to record your
FPA with the Register of Deeds of the counties in North Carolina
where you reside or own real estate.
Duration of a FPA
A FPA only becomes effective when you say it will, and the
language used therein determines if it will be effective
immediately or only upon your incapacity. A FPA that goes into
effect as soon as you sign it is called a “durable” FPA. With a
durable FPA, there is no waiting period or any determination of
incapacity required before your agent has the ability to manage
your financial affairs. Many spouses have durable FPAs for each
other in case something happens to one of them. Others, instead,
specify that the FPA does not take effect unless your doctors
certify that you have become incapacitated and thereby unable to
manage your own affairs. This is called a “springing” FPA, as it
only springs into effect when needed, and allows you to keep
exclusive control over your affairs unless and until such an
event occurs.
At death, a FPA automatically terminates and your Last Will &
Testament becomes the controlling document over your assets and
other finances. Unless your FPA agent is also appointed as the
Executor in your Will, your agent will have no authority to
handle financial matters after your death, such as paying your
debts, making funeral or burial arrangements, or transferring
your property to the people who inherit it.
Your FPA also ends if:
• You revoke it. As long as you are mentally competent,
you can revoke a FPA at any time by performing certain acts of
revocation required by state law and providing notice to your
current agent that you have revoked his or her authority.
• A court invalidates your document. While rare, a court
may declare your document invalid if it concludes that you were
not mentally competent when you signed it, or that you were the
victim of fraud or undue influence.
• No agent is available. To avoid this problem, you can
name one or more alternate agents in your document if the first
agent designated is unable to serve.
The Extent of an Agent’s Authority
Commonly, people give their agent broad powers to handle all of
their finances. However, you can give your agent as much or as
little power as you wish. North Carolina law also provides
limitations that may prevent certain activities from being
carried out by your agent under your FPA. The best
recommendation is to specifically state all actions and powers
desired for your agent and consult with an experienced estate
planning attorney to discuss any unusual or more restrictive
powers desired to determine if they will be effective. Specific
areas of concern which may require special attention and
discussion are:
• transferring your authority to vote for business or financial
affairs
• creation or modification of a Last Will & Testament or trust
• changes to beneficiary designations of life insurance and
other retirement accounts
• gifting of funds to family members and others
• exercise any powers which would cause your assets to be
taxable to the agent
• exercise any power of appointment given to you in someone
else's Last Will and Testament or trust
However, there are also numerous actions you may want to
specifically authorize your agent to do which are typically
accepted within the general language used in an FPA. Some
examples include:
• use your assets to pay your everyday expenses and those of
your family
• buy, sell, maintain, pay taxes on, and mortgage real estate
and other property
• collect Social Security, Medicare, or other government
benefits
• invest and manage your money in stocks, bonds, and mutual
funds
• handle transactions with banks and other financial
institutions
• buy and sell insurance policies and annuities for you
• file and pay your taxes
• operate your business
Note that the agent is always required by North Carolina law to
act in your best interests, maintain accurate records, keep your
property separate from his or hers, and avoid conflicts of
interest.
Selecting Your Agent
A FPA can be a simple solution to many potential problems and
unforeseen circumstances that can arise during your life.
However, with the inherent power and authority transfer a FPA
delivers, it is of vital importance to carefully consider not
only those aspects mentioned above, but who you should select to
serve as your agent as well.
Only you can determine the best person to serve as your agent.
However, your choice needs to be someone you trust, as well as
someone who can competently carry out the tasks required. Many
people select their spouse as their first choice, and a child or
other relative as alternates. But, if your spouse is ill,
inexperienced in financial matters, or for some other reason
wouldn't be able to handle the responsibilities, it is best to
select someone else.
Recommendation
The FPA is a tremendously valuable life planning tool for an
individual. Like other estate planning documents, however, it
should be implemented only after having given full consideration
to all aspects of what you are signing and the effects it may
have on your life. To ensure the full value of a FPA is
realized, we recommend that it be incorporated as part of an
overall estate planning strategy devised with the advice and
counsel of a qualified attorney.
For additional information
regarding Power of Attorney contact Tom Lenfestey at (919)
250-2108 or
tlenfestey@smithdebnamlaw.com.
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The Rapson Rule
and The End of “Sweetheart Sales” Immigration reform is an emotional issue that evokes strong opinions. Most people agree that some level of reform is necessary, but disagree over the goals of that reform. On the one hand, U.S. businesses facing continuing labor shortages seek relief through an influx of foreign employees. On the other hand, the American public’s increased hostility towards undocumented immigrants fuels the call for increased border security and employer sanctions. These competing interests have driven the recent comprehensive immigration reform debate in the Senate. After a failed attempt to find a solution during the previous session, the Senate recently took up debate on what some labeled a “grand compromise” between those endorsing strict enforcement-only and those in favor of some form of legalization of the estimated millions of existing undocumented immigrants. This “compromise” ultimately failed.
As a frequent speaker on lender
compliance law, I have never failed to startle an audience with
the realization that they are exposed to claims of “commercial
unreasonableness” and related stiff statutory damages. Secured
lenders all too often are astonished to learn that the
nationwide 2001 revision to the Uniform Commercial Code included
an obscure provision discouraging “sweetheart sales” of
repossessed collateral. Buried in UCC §9-615(f), it can also be
found in any state’s commercial law (for example, North
Carolina’s version includes it at GS §25-9-615(f).)
What is a “sweetheart sale”? Imagine a collection manager whose
duties include the resale of collateral repossessed from
consumer debtors in default. After recovering a particularly
clean little red convertible, our manager receives a visit from
The Boss. It seems The Boss’s Princess Daughter has taken a
shine to that sports car. The Boss appears in the manager’s
office, checkbook in hand, ready to buy it on the spot and drive
it home tonight. After first casually discussing the manager’s
next performance review, The Boss mentions he has already looked
up the car’s wholesale book price, including some arbitrary
high-mileage deduction. He drops a check on the manager’s desk
for, say, 75% of the remainder, and puts his hand out for the
keys. As he sweeps out of the office, he graciously suggests the
title paperwork can catch up with him later. That is a
sweetheart sale.
Unwilling to suggest to The Boss that a better price for the car
should be available, our manager shrugs it off and calculates
the artificially increased deficiency he’ll pursue from the
borrower. Because too many such sweetheart sales by lenders to
their own “insiders” have resulted in inappropriate high
deficiency balances for debtors, when the UCC Permanent
Editorial Board met to draft the 2001 amendments, member Donald
J. Rapson championed the section that now bears his name.
Rapson recognized that no collection manager interested in a
successful career was ever likely to tell the Boss “No”. He also
recognized that lender management, Board members, and even its
rank-and-file employees would always have an interest in an
“employee discount” on particularly choice collateral. Rapson
also realized that the victim of such insider dealing is not
really the lender – it’s the borrower. A car or other collateral
sold for a sweetheart price to an insider means the borrower’s
liability for the deficiency (i.e., the uncollected balance not
satisfied by the proceeds of the collateral sale) is increased.
In fact, it may be the borrower’s equity in the car that is
sacrificed to please The Boss’s wallet. Since the cost of suing
and collecting a larger deficiency judgment from a defaulting
debtor is little different than pursuing a smaller one, there
was essentially little risk to the lender from a sweetheart
sale.
The 2001 amendment wisely did not seek simply to forbid resale
to “insiders.” Besides being inconsistent with a lender’s right
to buy repossessed collateral itself (UCC §9-610(c)) and the
lender’s limited right to accept collateral in outright
satisfaction of a debt (UCC §9-620), such a bar would have been
too easily evaded by “straw” sales to next-door neighbors. In
fact, the Rapson Rule does not even forbid the lender from
accepting as low a resale price as any Boss might hope or want.
The approach adopted in the Rapson Rule is far more clever.
Lenders remain free to resell any repossessed collateral at any
price to any insider. The catch, however, is that the deficiency
balance the borrower owes will be calculated not on any such
sweetheart price, but “based on the amount of proceeds that
would have been realized in a disposition to an [unrelated]
transferee” (UCC 9-615(f).) Translation: you can sell the
convertible to The Boss for 75% of wholesale if you want, but
you must credit the borrower’s account for 100% of the retail
price. The effect of the Rapson Rule is therefore to shift the
cost of such insider discounts to the lender, sheltering the
debtor from this practice.
What happens if the lender should sell a repo to an insider but
calculates the deficiency balance based on the low sweetheart
price instead of the full retail price? The answer lies in UCC
§9-625(c)(1) & (2), and is not pretty, especially in consumer
loans. The penalty for such an action is the actual loss
suffered by the debtor plus “an amount not less than the credit
service charge plus 10% of the principal amount of the
obligation [emphasis added].” This add-on equates to the sum of
all the interest that was to be paid during the life of the
loan, plus 10% of the amount borrowed. Practically speaking, the
cost to an offending lender grows even larger, as the borrower’s
liability for the deficiency balance also usually disappears in
any later litigation, along with the lender’s entire profit and,
at a minimum, its own legal fees.
In addition to being aware of the significant financial exposure
for failing to comply with the Rapson Rule, collection managers
should also take note that they now have the perfect tool to
deal with The Boss’s suggested sweetheart sale price. No longer
is it necessary to say “No” to Bosses, Board members, or
co-workers wanting an “insiders’ price”. Explaining to the
bargain-hunting insider (and to management) that the debtor’s
account must still be credited with the unquestionable full
retail amount, will generally dissuade even the most determined
bargain-hunter. Now the Boss is faced with a choice: explain to
an auditor why the debtor account was credited with an amount
greater than the amount of the check he wrote, pay full retail,
or walk away.
Specifically, the Rapson Rule is triggered “when the amount of
proceeds of disposition is significantly below the range of
proceeds that a complying disposition to a person other than the
secured party, a person related to the secured party, or a
secondary obligor would have brought” (UCC §9-615(f)(2).) While
a lender might find solace in demonstrating the sweetheart price
it took was within “the range of proceeds” it could have gotten
from an arm’s length sale to an outsider, continuing to do
business in ways recognized to attract scrutiny from the hostile
eyes of disappointed debtors and skeptical juries seems
short-sighted at best. Remember - lenders’ lawyers rarely work
for free, and the legal costs of a successful defense in a
Rapson Rule case can easily equal or exceed the potential
statutory damages.
The most complete remedy is really quite simple: a written
policy of no resale to “insiders,” unless at full retail price.
Without the financial incentive, interest in purchasing a
repossessed item will likely disappear, along with exposure to
litigation and related legal costs. After all, the only thing
worse than paying full price is paying lawyers to fix the
problem.
For additional information or questions on this topic contact
Frank Drake at (919) 250-2108 or
fdrake@smithdebnamlaw.com.
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Avoiding Pitfalls in
Immigration Law In law school, future attorneys are
taught how to make the best argument on behalf of clients, and
that every issue can be viewed in different ways. Indeed, our
standard judicial system is designed with that concept in mind.
Opposing parties get to bring their case into a courtroom,
present laws and arguments to the presiding judge, and await a
decision. In the end, we expect that justice will be achieved
when adversaries are afforded the opportunity to present their
case in the most favorable light.
In the immigration law arena, however, the opportunity to
present a client’s case is limited in various ways.
Adjudicators, consular officers, and immigration judges make
decisions within a complex framework that affords few rights to
the foreign individuals before them. In many instances,
particularly at consulates, counsel cannot be present during the
process to help clients present their case. In further contrast
to the standard judicial system, very limited appeals procedures
exist in immigration law.
To make matters worse, at first blush the immigration system can
seem simple– file a few forms, take a couple of passport photos,
and voila! In fact, immigration law is highly technical and
complex, and one small misstep along the way can lead to big
problems. At best, a denial will result in losing the high
filing fee paid to the government. In more grave situations, an
improper filing can lead to deportation. Wrong answers or
“little white lies” can cause admissibility problems in the
future. The potential for pitfalls is boundless.
Some clients have begun the process alone, but wisely recognize
the need to get help when a problem arises. In one situation, a
client sought our legal advise after filing for naturalization
(citizenship) on her own and running into problems. A few years
earlier, she had been arrested in North Carolina and charged
with a misdemeanor. In exchange for an admission to the offense,
she was permitted to participate in a “first offender” deferred
prosecution program offered by the state. At the successful
completion of the program, the charge was dismissed.
Believing that no conviction existed, the client completed the
naturalization petition stating that she had never been
arrested; had never been charged with committing any crime or
offense; and had never been convicted of a crime or offense.
Unfortunately, under immigration law, her earlier “admission”
was construed as a “conviction,” leading to an apparent failure
of the “Good Moral Character” requirement for citizenship.
Fortunately for this client, we were able to demonstrate to the
adjudicator a narrow exception within the immigration code for
this type of “conviction.”
The bigger concern was that her answers might be construed as
lying. “False testimony” can also preclude a finding of “Good
Moral Character” and derail hopes of naturalization. In the end,
we were able to present a convincing, thoughtful disclosure of
her circumstances to the adjudicator before any damage was done.
She is now a U.S. citizen.
Another recent matter involved a client seeking to bring his
fiancée to the United States from the Philippines. One logical
prerequisite for a fiancée visa is that the individuals must be
legally free to marry each other. In this case, the fiancée was
previously married, but her husband had disappeared some years
earlier. The government of the Philippines does not permit
divorce, and instead she was issued a judicial declaration of
absence or presumptive death “for all intents and purposes.”
Unfamiliar with this document and its legal effect, the U.S.
government issued a request for evidence, and the couple sought
our aid in responding to that request. Coordinating with our
clients’ legal counsel in the Philippines, we were able to
provide documents and legal authority to demonstrate that they
were in fact free to marry each other. The petition was approved
and forwarded to the consulate.
While not every case has a happy ending in the world of
immigration law, the foregoing cases provide just a few examples
of how solutions may be found, even when a client has started
down the immigration path before seeking legal counsel. Our
office is called upon to handle a wide variety of issues from
start to finish, including deportation defense, employment and
family based petitions, and student issues. For employers
needing assistance with immigration compliance, we offer
comprehensive services to include I-9 audits, ICE raid
preparation, and even media strategy development. Our job is to
apply creativity and critical thinking to our clients’ cases,
helping them avoid falling into the traps along the way.
For
additional information or questions regarding Immigration Law
contact Amanda L. Bryant at (919)250-2136 or
abryant@smithdebnamlaw.com.
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to Index i Julie Haviv
(2008, February 20), Home Loan Demand Plunges as Interest Rates
Soar, Reuters, visited February 20, 2008 <http://www.reuters.com/article/domesticNews/idUSN2033753520080220?feedType=RSS&feedName=
domesticNews.>
ii Dan Levy and Brian
Louis (2007, November 30), Housing Slump’s Third Year to be
‘Deepest’ Since WWII., Bloomberg.com, visited February 20, 2008,
< http://www.bloomberg.com/apps/news?pid=20601109&refer =home&sid=ah1avXfvpNak>
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