Monthly summary of mortgage activities, Oct. 2003

Monthly Summary of Mortgage Activities
Georgia Department of Banking and Finance
2990 Brandywine Road, Suite 200, Atlanta, GA 30341-5565
FOR THE PERIOD ENDING OCTOBER 2003
SUMMARY OF ACTIVITIES - MORTGAGE DIVISION WEBSITE: www.dbf.state.ga.us
----------------------------------------------------------------------------------------------------------------------------------------------------
ENFORCEMENT ACTIONS
From time to time, the Department has to resort to enforcement actions against those brokers and lenders who are unable or unwilling to comply with the Georgia Residential Mortgage Act (GRMA). These actions come in a variety of forms, have differing consequences, and are often used to achieve a desired goal. Some actions are used as a preventative or corrective measure. Some are merely punitive when it is determined that the licensee deliberately or through negligence violated our law.
The most useful tool available to the Department is the "Memorandum of Understanding". While many applicants object to entering into a MOU with the Department, these documents are often beneficial to them. A well written MOU allows the Department to say "Yes" where the circumstances would normally call for a "No" answer. MOU's are used in situations where there are questionable background issues (such as credit issues subject to legal action or appeal), employment issues, or situations where the proof required for a more punitive adverse action has not been fully developed. The Department benefits from a MOU because the applicant has to sign the form and acknowledge their responsibilities under the MOU. In addition, the applicant has to acknowledge the consequences for failing to provide the desired corrective measures. Since the document represents understanding among the parties, the existence of a MOU is usually not published in the Monthly Summary of Mortgage Activities.
Consent Agreements have a similar effect to the MOU; however, they are usually considered to be far more serious and restrictive. Also, they are often drafted by legal counsel. These are considered to be punitive in nature. Sometimes lenders will choose not to do business with a broker who is subject to a Consent Agreement. The existence of a Consent Agreement is published in our Monthly Summary.
A review of Rule 80-11-3-.01 will reveal a variety of monetary fines that are often levied for infractions of GRMA. Licensees never want to pay fines so it would be wise to review this regulation to become familiar with the types of infractions which are the most expensive. Some infractions receive a one-time fine, others are "tiered" in that each instance of the infraction results in its own separate fine. Some fines (such as the employment of felons) are accompanied by further actions such as a Cease and Desist Order (see below) and/or License Revocations. Fines levied by this Department are published in our Monthly Summary.
Cease and Desist Orders (C&D) are the most serious. These documents represent an order by this Department for a person who is performing acts covered by GRMA to immediately stop engaging in illegal activities such as employing felons, operating without a license, or doing business with unlicensed persons. Generally, licensed companies (partnerships, LLC's, sole proprietors, and etc.) who are issued a C&D must refrain from the prohibited activity, but their license remains active. However, many of these activities may or could also result on monetary

penalties and revocation of the license. Individuals who receive a Cease and Desist Order for engaging in activities requiring a license under GRMA but who do not have one will be barred from working in the residential mortgage industry for THREE YEARS. A listing of those persons receiving a Cease and Desist Order are published in each Monthly Summary. As with Consent Agreements, cautious licensees will avoid doing business with persons who have received such Orders.
The most punitive enforcement action is a revocation of the mortgage license. This is generally pursued against companies whose actions (business activities) pose a threat to Georgia consumers and generally prove to fall into those acts prohibited by the code.
CHANGE REPORTING
O.C.G.A. Section 7-1-1006 (e) requires that "Each licensee shall notify the Department in writing of any change in the address of the principal place of business or of any additional location of business in Georgia, any change in registered agent or registered office, any change of principal officer, director, contact person for consumer complaints, or ultimate equitable owner of 10 percent or more of any corporation or other entity licensed under this article, or of any material change in the licensee's financial statement. Notice of a change in address or an addition of a new location shall be submitted no later than 15 days before the change is made. Notice of other changes must be received by the Department no later than 30 business days after the change is effective."
It would appear that many licensees are failing to report the required changes noted above in compliance with this code section. It is important that the Department have a current contact and financial information on all licensees, including a current contact for consumer complaints. Forms are available on the internet at http://www.ganet.org/dbf/mortgage_forms.html to facilitate this required reporting. Failure to report certain changes, such as office relocations or a change in officers, can result in the imposition of fines. Fine amounts are noted in Department Regulation 80-11-3-.01.
RESPONSIBILITY FOR GEORGIA FAIR LENDING ACT (GAFLA)
Most licensees claim their intent is NOT to make high cost loans. ALL CREDITORS are responsible for testing loans to prove loans are not high cost loans. Please remember to do your test and put a copy in the loan file to prove you are not making high cost loans. You are a creditor if you are a processor, loan officer, broker or lender. Some brokers have never tested their loans because they rely on their lender, and some brokers have stopped testing their loans because the lender does not require them to test anymore. This reliance on the lender's calculation or advice should not occur. Creditors, as noted, are responsible for their compliance with GAFLA and should make their own calculations of the APR and Points and Fees to determine if the loan is or is not a high cost loan. Do not rely on others to do this for you because their test cannot protect you in a court of law.
NOTE: High cost loans are not prohibited. They may be made as long as they meet the requirements of GAFLA.
GEORGIA FAIR LENDING ACT - CHOICE OF ATTORNEY
The Georgia Fair Lending Act (GAFLA) allows attorneys' fees to be excluded from points and fees calculations if the borrower has the right to select the attorney from an approved list or otherwise. However, it should be noted that Department examiners have been instructed to include attorneys' fees in points and fees calculations if the licensee does not have documentation signed by the borrower indicating that the borrower had a choice in attorney. Therefore, it is in the best interest of the licensee to have this documentation in the file or on file to prevent such attorney fees from being included in points and fees calculations and inadvertently creating a high cost loan or violating GAFLA.

HIRING EMPLOYEES
As a licensee, it is important to realize that you are responsible for the persons you employ. That is why it is very important that, prior to employment, you conduct proper pre-employment checks with previous employers of the prospective employee, conduct background checks on covered employees, and verify that the person is qualified to work in the mortgage industry. By qualified, in this instance, it means that the individual does not have an outstanding Cease and Desist order issued against them by the Department. Regulation 80-11-.01 (10) states that: "Any licensee or registrant who employs any other person against whom a final Cease and Desist order has been issued within the preceding three (3) years, if such order was based on a violation of Code Section 7-1-1013 or based on the conducting of a mortgage business without a required license or exemption....shall be subject to a fine of $1,000 per such employee and their license or registration will be subject to revocation or suspension."
In order to determine if a prospective employee has an outstanding Cease and Desist order, please check the Department's listing of outstanding Orders at http://www.state.ga.us/dbf/cdorders.html. For individuals, you may enter last name first or part of a name, for example "jo" only for Jones, Johnson, etc. To see all outstanding Cease and Desist orders, simply leave the selection box blank and press "Submit Query".
This is a comprehensive listing of companies that have outstanding orders. It also lists individuals who, because of the outstanding order, are generally not permitted to be employed in the industry for a period of 3 years. Please review this list prior to hiring individuals to work for your business. In the event that you have a question with regard to conducting business with a company on the list, please contact this office.
VERIFYING LICENSED ENTITIES
Rule 80-11-4-.05 of the Mortgage Division Rules states, in part, that it is the licensee's responsibility to "know" that it is conducting business with a licensed entity.
You run the risk of conducting business with an unlicensed entity if you do not verify the license. The fine for "dealing with unlicensed persons" under Rule 80-11-3-.01 (4) is $1,000 per transaction and your license shall be subject to suspension or revocation. Anyone who purchases, sells, places for processing or transfers a mortgage loan or loan application to or from a person who is required to be licensed but is not properly licensed will be fined.
You can check the license status of any licensee by going to the Department's web site at http://www.ganet.org/dbf/mortgage.html . From there you can check by entering the licensee's name, license number, or city, or leave the selection box blank and you will get a complete listing of licensees. There is also an option to download the entire list into an Excel spreadsheet.
E-MAILING THE DEPARTMENT
The Department would like to encourage you to correspond with us using e-mail.
Providing written details in the e-mail regarding any questions or concerns you may have allows the Department to forward the request to the appropriate person who handles that area, and if sufficient details are provided in the request, that person can then more efficiently provide you an answer.
The e-mail address is dbfmort@dbf.state.ga.us
A detailed message which will be distributed to the proper individual will help us help you. In the event you still need additional information, please contact us by phone.

DISTRIBUTING THE MONTHLY SUMMARY
The Monthly Summary of Mortgage Activities is E-mailed each month to licensees. The Department requests that all licensees provide the Department a valid E-mail address in order to receive the Monthly Summary each month in a timely manner. For all other licensees, the Monthly Summary is available on the Department's website http://www.state.ga.us/dbf/bulletins.html each month. This delivers the Mortgage Summary to you more rapidly and efficiently. If you have not already provided the Department with your E-mail address, please contact the Mortgage Division at dbfmort@dbf.state.ga.us or at 770-986-1633 if you have any questions. Licenses issued in Georgia are subject to revocation, withdrawal or suspension. To verify the current status of a license call 770-986-1269 or check our web site at http://www.state.ga.us/dbf/
CEASE AND DESIST ORDERS - Issued
Community Home Loans, LLC,( license no. 16769), Smyrna, GA - Cease and Desist Order issued September 17, 2003 and became final on October 7, 2003.
Comprende Mortgage, Inc., Atlanta, GA - Cease and Desist Order issued September 16, 2003 and became final on October 16, 2003.
Effio, Patricia, Norcross, GA - Cease and Desist Order issued September 17, 2003 and became final on October 17, 2003.
Green's Marketing Services, Grovetown, GA - Cease and Desist Order issued September 17, 2003 and became final on October 17, 2003.
Hays, Ed, Atlanta, GA - Cease and Desist Order issued September 16, 2003 and became on October 16, 2003.
Mortgage Consultant Services, Inc., (license no. 16862), Jonesboro, GA - Cease and Desist Order issued September 17, 2003 and became final on October 7, 2003.
Mortgage Lenders Network USA, Inc.(license no. 12163), Middletown, CT - Cease and Desist Order issued October 22, 2003 and became final on October 22, 2003.
Parrott, Lilburn Leo, Marietta, GA - Cease and Desist Order issued September 17, 2003 and became final on October 17, 2003.
Shakur, Wesley, Norcross, GA - Cease and Desist Order issued September 17, 2003 and became final on October 17, 2003.
Thornton, Anthony, Smyrna, GA - Cease and Desist Order issued September 17, 2003 and became final on October 7, 2003.
Wayne Frier Home Center of Hinesville, Inc. (license no. 13909), Hinesville, GA - Cease and Desist Order issued September 18, 2003 and became final on October 20, 2003.
Yi, Mark, Norcross, GA - Cease and Desist Order issued September 17, 2003 and became final on October 17, 2003.
CEASE AND DESIST ORDER - Lifted
National Equity Corp., Irvine, CA (former license #11872) - Cease and Desist Order issued October 4, 2000 was LIFTED on October 21, 2003.

FINAL CONSENT ORDER None

LICENSEES/REGISTRANTS REVOKED, EXPIRED, SUSPENDED, WITHDRAWN OR DENIED IN OCTOBER 2003

ID#
5622 11778 12049 13180 13909 15248 15857 16438 17619 17970 18061 18253

NAME
MISRA GRP INC ALANTE' MTG INC AMER SOUTHERN FINL 1ST ONE LENDING CORP WAYNE FRIER HM CTR HINESV STERLING CAP MTG CO ASHTON WOODS MORTGAGE, LIGHTHOUSE LENDING HITS FINLS INC 1ST AMER HOMES INC MTG PROFESSIONALS LLC UNITED CAP LENDING LLC

CODE
LD BD BD LD BD LD LD BD BD BD BD BD

REVOKED

EXPIRED
10/01/2003 10/01/2003 10/02/2003

SUSPENDED

10/20/2003

WITHDRAWN
10/06/2003
10/03/2003 10/27/2003 10/03/2003 10/06/2003 10/03/2003 10/02/2003 10/03/2003

DENIED

TOTAL: 12

FINES ASSESSED IN OCTOBER 2003

ID#

ISSUE

DATE

FINE

PAID DATE

COMPANY NAME

CITY

ST

5633 5633 5633 5633

10/23/2003 10/23/2003 10/23/2003 10/23/2003

$1000. $1000. $1000. $2000.

Georgia Mortgage & Realty, LLC Georgia Mortgage & Realty, LLC Georgia Mortgage & Realty, LLC Georgia Mortgage & Realty, LLC

Sandy Springs

GA

Sandy Springs

GA

Sandy Springs

GA

Sandy Springs

GA

5633 5635 5737 5737

10/23/2003 10/16/2003 10/08/2003 10/08/2003

$500. $1000. $1000. $1000.

10/24/2003 10/31/2003 10/31/2003

Georgia Mortgage & Realty, LLC Century Mortgage Corporation Homeowners Service Center, Inc. Homeowners Service Center, Inc.

Sandy Springs

GA

Dunwoody

GA

MARIETTA

GA

MARIETTA

GA

5753

10/16/2003

$1000.

10/22/2003 Terrace Mortgage Company

Atlanta

GA

5783

10/06/2003

$2000.

Greater Atlanta Mortgage Company

Atlanta

GA

5783

10/06/2003

$3000.

Greater Atlanta Mortgage Company

Atlanta

GA

5783

10/06/2003

$1000.

Greater Atlanta Mortgage Company

Atlanta

GA

5783

10/06/2003

$1000.

Greater Atlanta Mortgage Company

Atlanta

GA

5783

10/06/2003

$1000.

Greater Atlanta Mortgage Company

Atlanta

GA

5783

10/06/2003

$1000.

Greater Atlanta Mortgage Company

Atlanta

GA

FINES ASSESSED IN OCTOBER 2003

ID#

ISSUE

DATE

FINE

PAID DATE

COMPANY NAME

CITY

ST

5783

10/06/2003

$500.

Greater Atlanta Mortgage Company

Atlanta

GA

5877

10/16/2003

$1000.

10/29/2003 U.S.A. Mortgage, Inc

Cleveland

TN

6058 6058 6058 6058

10/23/2003 10/23/2003 10/23/2003 10/23/2003

$1000. $1000. $2000.
$500.

Creative Home Funding, Inc. Creative Home Funding, Inc. Creative Home Funding, Inc. Creative Home Funding, Inc.

Lawrenceville

GA

Lawrenceville

GA

Lawrenceville

GA

Lawrenceville

GA

6199

10/16/2003

$1000.

Invest America Mortgage Corp.

Atlanta

GA

6977

10/07/2003

$1000.

Ameriquest Mortgage Company

Orange

CA

6977

10/07/2003

$1000.

Ameriquest Mortgage Company

Orange

CA

7115

10/16/2003

$1000.

10/22/2003 Allied Home Mortgage Capital Corporation

Houston

TX

7260

10/16/2003

$1000.

AAA Georgia Home Improvment Co.

Stockbridge

GA

7387

10/16/2003

$1000.

CMH Homes, Inc.

Maryville

TN

7443

10/08/2003

$500.

Vinyl Lite Industries Company, LLC

Savannah

GA

11800

10/01/2003

$1000.

10/10/2003 BDK Mortgage & Investments, Inc.

Martinez

GA

11822

10/16/2003

$1000.

American Business Mortgage Services, Inc.

Roseland

NJ

11888

10/21/2003

$1500.

TransLand Financial Services, Inc.

Maitland

FL

12150

10/06/2003

$500.

10/30/2003 First Carolina Financial, LLC

Marietta

GA

12150

10/06/2003

$1000.

10/30/2003 First Carolina Financial, LLC

Marietta

GA

12252

10/16/2003

$1000.

10/27/2003 American Mortgage Services, Inc.

Lawrenceville

GA

13499

10/08/2003

$2000.

11/05/2003 Private Capital Group, LLC (The)

Atlanta

GA

13499

10/08/2003

$500.

11/05/2003 Private Capital Group, LLC (The)

Atlanta

GA

13834

10/16/2003

$1000.

Lighthouse Funding Corporation

Tustin

CA

13967

10/16/2003

$1000.

10/23/2003 First Guaranty Mortgage Corporation

McLean

VA

14124 14124

10/08/2003 10/08/2003

$1000. $500.

10/30/2003 Homesource Mortgage, Inc. 10/30/2003 Homesource Mortgage, Inc.

Sugar Hill

GA

Sugar Hill

GA

14124 15056 15683 16181

10/08/2003 10/16/2003 10/16/2003 10/28/2003

$1000. $1000. $1000.
$500.

10/30/2003 10/22/2003 10/29/2003

Homesource Mortgage, Inc. Mortgage Capital Associates, Inc. Alliance Capital Corp. Loan Link Financial Services

Sugar Hill

GA

Los Angeles

CA

Levittown

NY

Aliso Viejo

CA

16597 16664 16682 16961

10/30/2003 10/03/2003 10/21/2003 10/16/2003

$1000. $2000. $1000. $1000.

UniMortgage, LLC

Jacksonville

FL

Best Mortgage and Financial Services, Inc.

Oak Brook

IL

Shirley A. Williams

East Ridge

TN

SouthMor Mortgage Corporation

Memphis

TN

17210 17298 17301 18271

10/09/2003 10/07/2003 10/16/2003 10/09/2003

$3000. $1000. $1000. $5000.

10/27/2003

Advantage Mortgage Service, LLC Heritage Loans, Inc. United Capital Mortgage Corporation Asset Direct Mortgage, LLC

Stone Mountain

GA

Doraville

GA

aurora

CO

Marietta

GA

18271 18271 18434

10/09/2003 10/09/2003 10/16/2003

$1000. $1000. $1000.

10/27/2003 10/27/2003

Asset Direct Mortgage, LLC Asset Direct Mortgage, LLC PFS Mortgage Loans, Inc.

Marietta

GA

Marietta

GA

Alpharetta

GA

FINE REASON
16 licensees fined for books & records 1 licensee fined for unapproved branch 2 licensees fined for acq. of 25% ownership without approval 2 licensees fined for employment of a felon 11 licensees fined for loans files not properly maintained 5 licensees fined for doing business with unlicensed entity 2 licensees fined for advertising violations 16 licensees fined for audit file late

LICENSEES/REGISTRANTS APPROVED OR REINSTATED IN OCTOBER 2003

ID# COMPANY NAME

CITY

6808 17505 18604 18605 18676 18679 18680 18681 18682 18684 18686 18688 18690 18691 18692 18695 18696 18698 18699 18702 18703 18704 18705 18707 18708

Crown Mortgage, Inc. * Gunjankumar C. Gandhi Neustar Financial Services, Inc. Landmac Financial Services, Mathew Scott Woodward Barbara Jo Collins Kevin A. Lang Brenda J. Ward Stephen A. Orton Oak Residential Finance, Inc. Processing Depot (The) Atlanta Financial Enterprises, Benefit Mortgage Company Paul E. Shelton, Jr. Mortgage Lending Solutions, Inc. Bach Consulting, Inc. Top Choice Mortgage, LLC Overflow Mortgage Processing, Long Beach City Mortgage Team One Mortgage Services, Gary Lorenza Wiggins John William Malott C & S Associates, LLC Georgia Patriot Mortgage, Inc. AV Financial Corporation

MARTINEZ SMYRNA OVERGAARD STONE MOUNTAIN FAIRBURN NORCROSS SAVANNAH JONESBORO ALPHARETTA CANTON TUCKER MARIETTA CARROLLTON MCDONOUGH BUFORD DESTIN ROSWELL KENNESAW EL SEGUNDO ROSWELL NEWNAN SUWANEE ATLANTA MARIETTA SUWANEE

ST MB CODE
GA L GA B AZ L GA B GA B GA B GA B GA B GA B GA B GA P GA B GA P GA B GA B FL B GA B GA P CA B GA L GA B GA B GA B GA B GA B

ORIGINAL APPROVAL
02/25/1994 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003

RENEWAL
10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003

REINSTATED

LICENSEES/REGISTRANTS APPROVED OR REINSTATED IN OCTOBER 2003

ID# COMPANY NAME

18728 18729 18730 18732 18733 18734 18735 18736 18737 18738 18739 18740 18741 17306 17530 18531 18583 18639 18648 18665 18726 14127 18701 18709 18746 18748 18749 18750 18751 16334 18607 18657 18677 18763
6335 16552
6392 12265 13910 15115
7033

Tony Lee Morgan Mark William Harden Robin Bentley Charisse Jones Hunter Frances Keen Myers Sean M. Perren Jason Christopher Sproull John Mark Butler John Henry Henderson Lori Smith Johnson Trinity Funding Group, LLC Direct Funding, Incorporated All Mortgages Of Georgia, LLC Manufirst Mortgage, LLC + First Discount Mtg, LLC * Rita Celeste Johnson Kevin M. Cassidy Katherine G. Davis Platinum Processing, Inc. Lake View Mortgage, Inc. Moody Mortgage Corporation Centurion Mortgage, Inc. * Johnny Milton Mays Bergin Financial, Inc. Adams Processing Services, Prime Mortgage Financial, Inc. Bradley Scott Spieth Mortgage Land, Inc. Foundation Mortgage HomePlace Mtg * Ibex Networks, Inc. Georgia Residential Mortgage, Taryn Louise Lawrence Southpoint Mortgage CitiFinancial Services, Inc. # ARK-LA-TEX Finl * Edgar H. Walker Pipeline Lending Corporation Donald E. Harris All-In-One-Mortgage Company Mortgage Connection, LLC (The)

CITY
SNELLVILLE ATLANTA MORROW SNELLVILLE SUMMERVILLE MARIETTA LAFAYETTE DUBLIN HIRAM MACON FAYETTEVILLE SNELLVILLE CUMMING PERRY ATLANTA GRIFFIN LAWRENCEVILLE ATLANTA DACULA VILLA RICA HINESVILLE KENNESAW MACON SOUTHFIELD GRIFFIN SOUTHBOROUGH CUMMING NORCROSS COLUMBIA KENNESAW SANTA ANA DECATUR STONE MOUNTAIN NEWNAN BALTIMORE FRISCO MARIETTA SMYRNA FAIRBURN SMYRNA SMYRNA

ST MB CODE
GA B GA B GA B GA B GA B GA B GA B GA B GA B GA B GA P GA B GA B GA B GA L GA B GA B GA B GA B GA B GA B GA L GA B MI L GA P MA L GA B GA B SC B GA L CA L GA B GA B GA B MD R TX L GA B GA B GA B GA B GA B

ORIGINAL APPROVAL
10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 06/07/2002 09/06/2002 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 12/18/1998 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 03/16/2001 10/24/2003 10/24/2003 10/24/2003 10/24/2003 06/18/1993 07/06/2001 06/25/1993 02/21/1997 10/02/1998 10/29/1999 11/04/1994

RENEWAL
10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/03/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/10/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/17/2003 10/24/2003 10/24/2003 10/24/2003 10/24/2003 10/24/2003 10/31/2003 10/31/2003 10/03/2003 10/03/2003 10/03/2003 10/10/2003 10/24/2003

REINSTATED
10/03/2003 10/03/2003 10/03/2003 10/10/2003 10/24/2003

TOTAL: 66

B = BROKER L = LENDER R = REGISTRANT

+ Downgrade Lender to Broker Downgrade Registrant to Lender * Upgrade Broker to Lender # Upgrade Lender to Registrant