1

Office PoliciesOffice PoliciesOffice PoliciesOffice Policies ManualManualManualManual

Page 2: Welcome- Mission Statement

Page 3-8: General Guidelines

Page 9-10: Ten DOs and DON’Ts to Know in a Real Estate Transaction Page 11-13: Advertising, Signs, and Business Card Policies

Page 14-15: Policy for Do Not Call List Compliance and Telemarketing

Page 16-17: Anti-Money Laundering Program Requirements

Page 18: Advertising and Marketing Submission Form

Page 19-20: Predatory Lending Prevention and Zero Tolerance for Loan Fraud

Page 21: Payment to Corporations

Page 22: Commission Disbursement Request

Page 23-25: Compliance/Quality Control Checklist: Real Estate Sale

Page 26-28: Compliance/Quality Control Checklist: Mortgage File Page 29: Affiliated Business Arrangement and Dual Compensation Disclosure

Page 30: Addendum to Disclosure Regarding Real Estate Agency Relationships Page 31: Addendum to Statewide Buyer and Seller Advisory

Page 32-39: Current List of Approved Lenders

Page 40-41: List of Contacts

Page 42: Acknowledgement

-

2

Welcome- Mission Statement

It is our pleasure to welcome you aboard. Primary Benefit Properties and Primary Benefit Lending view our broker-salesperson relationship as a partnership. You work with us, not for us. The company operates on a principle of respect for the Associate-Licensee and recognition that you supply the business that keeps the company operating. We provide a business platform which allows associates to conduct their own business independently, benefiting from the ability to conduct both loan and sales transactions. We aim to become one of the premier players in the industry and hope you promote your business and the company accordingly. As your broker has taken steps to take care of you, we ask that you in turn take care of your broker. The low cost, flat fee concept is made possible through the strict compliance and cooperation of the company’s associates with our guidelines. It is important to place the needs of your clients first, always remembering your fiduciary duty, and acting with a helpful compassion. Your demeanor in helping your clients should reflect a business philosophy that you want to earn a lifetime client who will refer to you their family and friends. Always emphasize honesty, service, and professionalism. Conflicts are rare, but if a problem should arise, please make the corporate office aware of it as quickly as possible so that it can be resolved. We like to solve problems before they become problems. Claims against the company increase its future costs and jeopardize the commission structure that can be offered. It is important that our associates adopt our business principles, and understand that violations can be cause for termination of our contract. We ask that you read through this booklet and act in accordance with its guidelines.

We hope your affiliation with our company is the beginning of a long and mutually prosperous partnership. Welcome aboard!

B

3

General Guidelines

1. Associate-Licensee shall conduct mortgage business only in the name of “Primary Benefit Lending” and real estate sales only in the name of “Primary Benefit Properties.” Associate-Licensee shall not use an unlicensed false or fictitious business name. Use only the corporate address on all mortgage paperwork. You can use your own contact phone number and fax number.

2. If Associate-Licensee’s work location is a commercial office space, it needs to

be licensed by broker as a branch office. Associate-Licensee to immediately notify broker of any change of address. You will receive a Branch License certificate from the DRE which must be displayed at your location. Branch locations must also post a copy of the Fair Lending Notice (RE 867A) in a conspicuous place for public inspection. There is a $15 replacement fee for lost Branch License certificates.

3. Broker does not maintain a trust fund account, all deposit checks should be

written directly to the escrow company being used, not to the broker. Do not collect escrow checks, clients should send them directly to escrow. Any checks which are collected shall be recorded in a log of all trust funds received not placed in the broker’s trust account. Never collect any fees in advance of providing the service or closing the transaction. Third party fees such as for credit reports or appraisals can only be charged through the closing if the broker has paid them in advance.

4. Copies of all closed transactions, listings, purchase contracts, deposit slips, signed loan applications, or other documents executed in connection

with any transaction for which a real estate license is required to be

provided to broker and maintained on file for three years. The retention period shall run from the date of the closing of the transaction or from the date of the loan application if the transaction is not consummated. Upon taking a

listing or filling out a purchase contract, please return copies of all

paperwork to the corporate office within 48 hours. It is preferable to the corporate office to receive the file electronically scanned in PDF format. If you cannot convert the file yourself, it can be faxed to a special fax number. Contact the corporate office to have a fax cover page emailed to you when you have a file ready to fax. Agents are also required to keep copies of the files for 3 years. All files and documents pertaining to listings, leads and transactions are the property of the broker.

)

4

5. Associate-Licensee shall notify broker when entering a transaction requiring a real estate license (mortgage or sale) upon opening escrow. A phone call or email is sufficient. Broker’s copy of escrow instructions should be sent as soon as possible. You should also provide a pipeline report at least once a month. Agent shall not interfere with or impede in any way the broker’s supervisory duty as outlined by the Dept. of Real Estate and agrees to cooperate fully in keeping broker informed of all activities which require a real estate license.

6. Associate-Licensee shall provide one or both of the enclosed

Compliance/Quality Control Checklists as indicated when turning in a file for payment on a commission. Items needed on checklist must be included

before Associate-Licensee can receive compensation on the commission.

Please stack in order for quicker review and payment.

7. Commissions will be paid as soon as possible. If a hold is placed upon a

commission check by the broker’s bank, the funds must clear before Associate-Licensee can receive their check. Escrow can wire funds for quicker payment, highly recommended for large commissions. The corporate office must also have sufficient time to review that the file is complete. Normal turn time should be 24 to 48 hours but can be same day. Files must

be turned in prior to the close of escrow ensure that the file is in full

compliance with the law and funds can be disbursed rapidly.

8. Associate-Licensees who engage in real estate sales transactions shall join the Association of Realtors and shall comply with all applicable regulations and codes of ethics.

9. For any loan which requires asset verification or liquid cash reserves, the loan file must contain an additional Verification of Deposit (VOD) dated

within 10 days of the funding before the loan officer’s commission can be

distributed. This will be true regardless of whether or not the lender requires it, or whether or not the actual bank statements are already in the file.

10. All broker closing packages and commission checks must be delivered to the

corporate office directly from escrow. Associate-Licensee must obtain permission from broker to pick up and hand deliver package.

11. If broker is earning a commission representing a buyer or seller in a real estate

sales transaction and also earning a commission on the mortgage, that fact

)

5

must be disclosed to all parties within 24 hours of undertaking that task.

The DRE guideline reads as follows:

“A real estate licensee who acts as the agent for either party in a

transaction for the sale, lease or exchange of real property, a business

opportunity or a mobile home, and receives, or anticipates receiving,

compensation for securing a loan to finance the transaction, must disclose

to both parties to the transaction, prior to closing, the form, amount and

source of compensation received or expected.”

It is also necessary to disclose that the two separate business names are one entity. We have combined all necessary disclosure requirements into our

Affiliated Business Arrangement and Dual Compensation Disclosure included in this booklet. Both parties to the transaction must sign a copy of this form prior to the close of escrow when our company is doing both the loan and the sale. The requirement regarding “form, amount, and source” is satisfied by the delivery of the HUD-1 closing statement prior to the close of escrow.

12. We do not perform any type of loan modification activity. No licensed agent of this company shall engage in, advertise, or collect money for such services, or for the referral of any such services.

13. If anything out of the ordinary is occurring in your transaction (such as early release of funds, buyer electing not to do an inspection, short sale, seller giving credit instead of doing repairs, licensee or relative is a principal, etc.)

please contact the corporate office to see if any further disclosure forms

are needed whenever you are unsure. The corporate office has access to extensive legal resources and might save you hours spent defending yourself in litigation with a five minute phone call. Please notify the broker of any

issues prior to the close of escrow.

14. Unlicensed administrative assistants can perform a variety of activities to assist real estate licensees in transactions, however, they may not perform

any activity which requires a real estate license. In this regard, when unlicensed assistants are employed, it is essential that they be provided adequate supervision to ensure that the proper limitations are placed upon them so they do not perform activities which require a real estate license. Associate-Licensees that employ unlicensed assistants are strongly cautioned to be familiar with sections 10130-10149 of the Business and Professions Code, and advised that their assistants are not employed by the broker. Compensation arrangements between Associate-Licensees and their assistants

)

6

shall comply with proper tax reporting and employment regulations, and maintain a separate agreement from that of the broker and Associate-Licensee. Non-licensed persons can be employed by Associate-Licensee to assist the broker in meeting the broker’s obligations to its customers in residential mortgage loan transactions provided the employee does not participate in any negotiations occurring between the principals.

15. There is no single loan program that is right for every borrower. Each

loan program has its benefits and its limitations. It is extremely important that borrowers are properly counseled as to the features of the loans available and the potential pitfalls of the loan they may choose. The DRE states the following:

“It is the fiduciary duty of each licensee who represents the borrower in

obtaining a loan to completely explain the terms and discuss the relative

merits and risks of these loan products well before the point of signing

loan documents."

This is especially important regarding subprime loans, option arms, interest only loans, and short term fixed rate or adjustable loans. If the loan officer does his job properly, no borrower should ever have cause to contact us in the future claiming that they have been surprised by something pertaining to their loan terms. Please remember to keep your clients best interest at heart.

16. If borrowers are charged for items such as credit reports and shipping fees,

you can charge no more than the actual fees incurred, and invoices must be included with the final loan file. Fee can only be charged if it was paid for prior to the close of escrow.

17. Expected rebates must be disclosed on MLDS / GFE forms. To be in

compliance with an auditor and the DRE, the following three items should be reasonably accurate in a loan file:

1. The loan application is checked for signatures of the licensed interviewer and the borrower, along with the date. 2. The Mortgage Loan Disclosure Statement (MLDS) is then checked for proof it was mailed or given to the borrower within three (3) business days from the date on the loan application, along with the signature of the licensed broker or broker representative and the date to prove the borrower signed it. 3. The auditor will then compare the yield spread premium (YSP) listed on the bottom of the first page of the MLDS with the closing statement (HUD-1) to verify the YSP was disclosed. A listing of zero points in the MLDS

)

7

such as 0-3 is not acceptable, especially when the “800” series of the HUD-1 indicates the broker is getting $1,500 or less and the lender is a known Sub-Prime lender that pays YSP as a matter of course.

18. Most lenders require that a rebate paid to the broker must be repaid if the borrower pays off the loan in full within 6 months. Please make your borrowers aware that any loan should not be paid off in full or refinanced within the first 6 months of the loan. If a repayment of a rebate is required, Associate-Licensee is responsible for the repayment.

19. You must have a client’s signed authorization to retrieve a copy of his credit

report. The credit providers perform random audits and you must be able to show that you were authorized to pull the credit report.

20. Valid DRE salesperson’s license certificate must be held at corporate office in

order for Associate-Licensee to engage in activities requiring a license.

21. Do not make any changes to the corporate logo in its authorized uses.

22. Anti Trust Issues & Violations-Knowledge of & No Tolerance Policy: Federal and State anti-trust laws prohibit brokers from conspiring to fix prices, engage in boycotts, allocate customers or markets or establish tie-in agreements. Brokers do not have a ‘standard’ commission. No salesperson with our company shall suggest to a seller or buyer that there is a ‘standard’ rate charged in this area. There is no standard commission rate. Salespeople should never suggest to a competing brokerage that if they perform or refuse to perform a certain service that the brokerages in our area will ‘boycott’ them. Any of these acts could be construed as a violation of Anti-Trust laws and subject the individual and our company to severe civil and criminal penalties. Our company will not tolerate any Anti Trust Violations. This is grounds for immediate termination. We recommend our sales staff and employees be well informed of all current anti-trust laws.

23. Please use the Addendum to Disclosure Regarding Real Estate Agency

Relationships included with this booklet with each real estate transaction.

24. Listing contracts must contain a termination date and must disclose the negotiability of commissions.

25. When a salesperson buys or sells real estate for himself, the seller or buyer

must be informed about the salesperson’s license status, and must be aware the salesperson is not representing the interests of either party. To protect

)

8

yourselves and our company this fact must be clearly disclosed early, often, in the contract for purchase, and in all discussions.

26. Associate-Licensee to be familiar with federal and state laws relating to the

prohibition of discrimination and understand that violation of these laws can result in termination and loss of licensing.

27. Associate-Licensee to be familiar with Real Estate Law and Subdivided Lands

Law, Regulations of the Real Estate Commissioner, and Business and Professions Code as they pertain to actions requiring a real estate license.

28. Contents of this policy booklet are updated periodically. Updated booklet can

be emailed or faxed to Associate-Licensee upon request. 29. Associate-Licensees that engage in loan origination must be registered with

the NMLS and have an endorsement on their DRE licenses, and they must be sponsored on the NMLS system by our company. Broker will review NMLS eligibility periodically and be automatically notified by the NMLS system when any change in status occurs. You must also file form 886 online with the DRE within 30 days of commencing activity. Associate-Licensees who act in defiance of company, state, or national guidelines are subject to termination, license suspension, and possibly criminal prosecution. Agents are independent contractors and are not employees, thus only lender paid fees can be earned and paid to the agents. If any other fees are earned by being paid from anyone other than the lender, those fees cannot be paid to the agent.

30. Agents acknowledge that they are independent contractors and cannot be

considered employees or be paid salaries as employees. All commissions earned must comply with Federal and State standards regarding payment to salespersons as independent contractors. Agents cannot earn commissions which require payment as salaries or as employees. Any such commissions earned are the property of the broker.

)

9

Ten DOs and DON’Ts to Know in a Real Estate Transaction

1. As the listing agent, DO have the seller sign and verify the information that is submitted to the Multiple Listing Service. Protect yourself and have the seller's sign the MLS report before you submit the information to your MLS.

2. "Per Telephone Call" Signatures- DO NOT DO IT. The buyer or seller should always sign all legally binding documents such as the purchase agreement or counter-offer. An agent's signature for their buyer or seller followed by the words "per telephone call" is not sufficient to forma legally binding document and will not stand up in court. Get a signature! We are in an age with fax machines at the tip of our hands. All aspects of a real estate transaction are critical, important items need to be signed by the buyer and seller.

3. DO get a release agreement. If you agree to a settlement or condition of the property, contact the corporate office to obtain an appropriately drafted Settlement and Release Form and have both parties sign. Often sellers will credit the buyers for a condition of the property. For the seller's protection, have the buyers sign a settlement and release form stating that a settlement of x amount of dollars was agreed to for x condition. With this form, the buyers are on notice that they have agreed to this dollar amount and therefore will not hold the sellers liable for damages later for that condition.

4. Agents- DO your inspection. Place yourself at the property. Even if the house is flawless, find something to write in the agent's portion of the TDS confirming your visual inspection at the property. DO NOT write only, "Buyer should get Physical Inspection" as the statement fails to prove your visual inspection.

5. DO NOT go outside of your profession. If you see a crack in the slab, simply write, "crack in slab". DO NOT try to guess what caused the crack. Do not perform inspections of inaccessible areas such as roofs, attics, and crawl spaces. Remember your job is to view accessible areas. If you represent the buyer and are advised that an issue may exist within an inaccessible area such as a roof, attic or crawl space, urge your buyer in writing to have the appropriate professional inspect the condition.

6. Sellers- DO have the Buyers get a professional inspection. It is advised to make it a condition of the sale of your property, the buyers have a professional home inspection completed by an ASHI or CREIA certified home inspector. DO NOT identify the specific inspector, rather merely require that the buyer select an ASHI or CREIA certified inspector. Inspectors from these agencies are held to a higher standard of care. DO NOT let the buyer skip a home inspection. Defects or conditions of the property that arise later, may come back to haunt the seller because it was not addressed before the transfer of the property.

)

10

7. DO use a (3) Step Disclosure Process. Anytime you are making a material representation as to the condition of a property and you do not know the statement is true for a fact, use the following process in written form. For example, if your seller represents a new roof was installed by a licensed contractor five-years ago, do as follows: FIRST: Identify the source of statement. SECOND: Disclaim verification and/or accuracy and validity of the third-party statement. THIRD: Urge Buyer to independently confirm the statement.

Under this example, the disclosure would state:

(1) "Per Seller, a new roof was installed by licensed contractor 5 years ago." (2) "Agent has not, nor shall they verify Seller's statements as to the roof." (3) "Buyer is urged to perform their independent investigation to confirm Seller's statements as to the roof."

8. DO consider the appropriate time frame for Notice(s) to Perform. The Notice to Perform aspect of the purchase agreement is a very potent clause. Bear in mind that if the buyer agrees to the standard 24-hour notice period in the purchase agreement, this may later come back to haunt the buyer and buyer's agent. For example, if the notice to perform contains the standard 24-hour period, depending upon the buyer's and their agent's availability, they may both have enough time to consider removal of the contingency and default under this time period. As such, when representing buyers, consider using a longer period such as 72 hours.

9. DO use the appropriate form for increased deposits subject to Liquidated Damages Clause. The Liquidated Damages Clause in a residential purchase agreement only applies to initial deposit monies. If your seller wants the buyer to increase their deposit with the increased deposit subject to the Liquidated Damages Clause, the purchase agreement mandates that the parties use the CAR- RID form. The higher the amount that is subject to liquidated damages, the greater the protection to the seller. Similarly, the lower the amount of the deposit subject to liquidated damages, the less money the buyer stands to lose if they inexcusably fail to close the transaction.

10. DO call the corporate office. As we know, several items pop up in the course of a transaction. If you face any situation that you are unsure of, do not hesitate to place a call to the corporate office to clarify the situation PRIOR TO THE CLOSE OF ESCROW. The call may take as little as five minutes and save you several months in litigation as well as the payment of your deductible.

)

11

Advertising, Real Estate Signs, and Business Card Policies

Advertising: All advertising, including but not limited to print, radio, internet, and/or direct mail, must be reviewed and approved by Mazlat, Inc. prior to start of any advertising or marketing materials. We suggest you do not commit to any expenses related to ads prior to approval. We will not be responsible for costs you may have incurred on non-approved advertising. Email your Advertising Submission Form along with a copy of the proposed advertisement to rslepack@gmail.com, or fax to (888) 575-3279 for review. We will email you a confirmation of receipt of your proposed ads. For ALL radio and television ads please submit an audio tape and/or video tape respectively along with the submission form. The corporate office will return a faxed approval or denial with revisions if any. It is strongly recommended you keep a copy of the approved advertising in your file. Advertising discovered in circulation without prior approval is cause for immediate termination of your Independent Contractor agreement. -Ads must include either one of these names: “Mazlat, Inc.,” “Primary Benefit Properties,” or “Primary Benefit Lending” followed by this text “Real Estate Broker, California Department of Real Estate Broker #01462056.” -The following terminology is prohibited: "Your loan is guaranteed" "You can skip mortgage payments” "No points, no fee loan" "We guarantee the lowest rate" “We guarantee a specific rate.” -The following disclaimer must appear in ALL print ads or Internet ads: “Loan approval is not guaranteed and is subject to verification of specific information requested at time of application. Specified rates may not be available for all borrowers. Rates subject to change.” -If there is a representation that loans are available to a maximum percentage of market value, you must state how the market value will be determined. No implication that the borrower will be able to obtain a loan without deductions from principal or payment of commissions, costs or expenses and no representation that a loan can be approved by telephone. -No representation that credit rating or other personal financial data would not be a factor unless this is a true statement.

)

12

- If the APR is disclosed and is subject to increase after initial term, this must be disclosed although the amount of the increase, the limits and the effect on the payment schedule does NOT need to be disclosed.

-If an interest rate is stated, the corresponding APR must be stated in a visible manner.

-The following are "trigger terms": • Amount of percentage of down payment • Amount of any one payment • Amount of any finance charge • # of payments or period of repayment If any of the above mentioned "trigger terms" appear in the advertisement, the following terms must also appear as applicable: • Amount or percentage of down payment • Terms of repayment (ex: $359 for 48 months) • APR (Annual Percentage Rate)

-Also, under DRE regulations, if you include specific payment amount, you must include the following in equally prominent disclosures: • Principal amount of loan • Simple annual interest rate • APR • Number, amount and period of payments scheduled to date of maturity • Amount of balloon payment, if applicable

-If you include a specific installment payment, interest rate, APR or other provision of a loan, you must state whether it is available for first loans, junior loans or both first and junior loans. -Adjustable Rate Loans: Per the DRE, you must state how long the initial interest rate will be in effect, how often the rates may adjust and by how much. Also, if there is the potential for negative amortization (deferred interest), you must conspicuously disclose this. -No advertising that looks like a check. -Pursuant to HUD’s TI letters 434 and 448, following are some additional guidelines for advertising: • Do not use the term HUD or FHA or Department of Housing & Urban Development in the advertising or the FHA logo. • No advertising should say "FHA approved lender" or give any impression that broker is approved by the FHA.

)

13

• Do not suggest that you work for the FHA Division of brokerage. • The name of the broker must be prominently displayed. • Do not imply that the advertising is an “official government notice” or use the terms “Public Notice” or “Important Property Owner Notification or Important Property Information Inside” • Do not state or imply that Title I or II loans are a grant program or a government assistance program. • Do not state or imply that Title I or II is a special program or provides special benefits for a particular area or for a particular age group. • Do not state or imply that funding for the program is limited in amount or is only available for a limited time period. • Do not state or imply that the advertisement is a government survey. • Do not state that the borrowers are pre-approved or that their property is pre-approved. • Do not state that the loans are insured. • Do not state that no equity is required or no appraisal is required, unless the advertisement makes clear the conditions under which these are not required. • All information posted on a website qualifies as advertising. All website information must also be reviewed by management prior to posting.

Real Estate Signs:

In an effort to promote branding and increase visibility of our services, salespersons must use the company approved design for their real estate signs used in listing property. The signs will contain your personalized name and contact information. Please see the List of Contacts for the information you need to have your signs printed. Always be sure to comply with local sign ordinances.

Business Cards: Business cards are a form of advertising and must be in compliance with applicable laws. The company recognizes that their associates have a variety of preferences in business card designs and affords them a great deal of freedom in choosing their own design. Although we prefer you choose the company’s design which is in the same style as the for sale signs, you may choose any design which is in compliance with DRE regulations. Please submit your design to the corporate office for approval prior to printing. Please see the List of Contacts for card design contact information.

)

14

Policy for Do Not Call List Compliance and Telemarketing

We have established and implemented the following written policy and procedures for maintaining a do-not-call list. It is our intent to honor anyone’s do-not-call request in a systematic and timely manner. It is also our intent to fully comply with any and all applicable do-not-call rules as a matter of course in our routine business practices. These rules are generally set forth at sections 64.1200 et seq. of Title 47 of the Code of Federal Regulations pertaining to the Telephone Consumer Protection Act of 1991.

Our company requires our sales staff and other personnel to read, understand, and strictly adhere to the following rules and procedures:

• Checking Company-Specific Do-Not-Call List: Do not initiate any call to any home or cell phone number for the purpose of soliciting business unless you first check our company-specific do-not-call list if any. There is no exception to this rule for calls made based on written permission, established business relationship, or personal relationship. Our company will provide you with a copy of, or instructions for accessing, our company-specific do-not-call list if any. If you do not have a copy of or access to our company-specific do-not-call list, inform your broker or manager immediately.

• Honoring Do-Not-Call Requests: If the purpose of your call is to solicit business, you must refrain from calling anyone’s home or cell phone number listed on our company-specific do-not-call list if any. Honor any do-not-call request for five years, unless the person asks to be removed. Do not share our company’s do-not-call list with anyone outside our company.

• Verbal Do-Not-Call Requests: If anyone you speak with over the telephone or in person requests for our company to refrain from calling that person, you must immediately write down or otherwise record the following information: (1) the person’s name, if provided; (2) the person’s home and/or cell phone number(s) to be placed on our company-specific do-not-call list; (3) the date and time of the do-not-call request; and (4) any other information deemed necessary. Immediately place this information on our company-specific do-not-call list and inform your broker or manager accordingly. Your immediate attention in this matter is essential because our company must honor the do-not-call request within a reasonable time, not to exceed 30 days from the date of the request.

• Written Do-Not-Call Requests: If you receive a do-not-call request by mail, fax, e-mail, or any other method, you should date and time stamp the do-not-call request. Immediately place the information on our company-specific do-not-call list and inform your broker or manager accordingly.

• Requests for Our Do-Not-Call Policy: If you receive any request for our company’s written policy for maintaining a do-not-call list, you must immediately bring this to the attention of your broker or manager for proper handling.

)

15

• Our Affiliated Entities: Absent a contrary request from a customer, a do-not-call request applies to our company and not our affiliated entities, if any, unless the customer reasonably expects them to be included given the identification of the caller and the product being advertised.

Associate-Licensee assumes any liability in performing marketing by telephone and will act in accordance with all applicable state and federal laws and regulations. Any services which are contracted will be done in the name of the Associate-Licensee or a corporation or separate entity. Services may not be contracted in the name of the broker. Calls may not be made on behalf of the broker. Associate-Licensee is solely responsible for any fines incurred for any violations of the Do Not Call registry or telemarketing laws.

)

16

Anti Money Laundering Program Requirements for Mortgage lenders and Originators

On February 7, 2012, the Financial Crimes Enforcement Network (FinCEN), which is a

department of the U.S. Department of the Treasury, issued the Anti-Money Laundering Program

and Suspicious Activity Report Filing Requirements for Residential Mortgage Lenders and

Originators (SAR Rule). The Final Rule includes Residential Mortgage Lenders and Residential

Mortgage Originators in the definition of a loan or finance company and requires these

companies to comply with the anti-money laundering programs (AML) and report suspicious

activities (SAR) under the Bank Secrecy Act (BSA).

Effective Date The SAR Rule went into effect on April 16, 2012. Compliance with the SAR Rule is required by

August 13, 2012.

Why require Mortgage Lenders and Mortgage Brokers to comply? FinCEN has issued studies over the last several years, which analyzed SARs reporting suspected

mortgage fraud and money laundering. These SARs, which were filed by depository institutions,

included mortgage lenders and/or mortgage brokers. FinCEN believes that these companies “are

in a unique position to assess and identify money laundering risks and fraud while directly

assisting consumers with their financial needs and protecting the sector from the abuses of

financial crime”.

SAR Requirements Mortgage lenders and mortgage brokers are now required to file a report to FinCEN of any

suspicious transaction relevant to a possible violation of law or regulation. In addition, they may

also file a report of any suspicious transaction that they believe is relevant to the possible

violation of any law or regulation, but whose reporting is not required.

Below are a few of the SAR requirement elements.

Reporting

Under the SAR Rule, there are four categories of transactions that require reporting. Section

1029.320(2) of the SAR Rule states the following:

“A transaction requires reporting under this section if it is conducted or attempted by, at, or

through a loan or finance company, it involves or aggregates funds or other assets of at least

$5,000, and the loan or finance company knows, suspects, or has reason to suspect that the

transaction (or a pattern of transactions of which the transaction is a part):

(i) Involves funds derived from illegal activity or is intended or conducted in order to

hide or disguise funds or assets derived from illegal activity (including, without limitation, the

ownership, nature, source, location, or control of such funds or assets) as part of a plan to

17

violate or evade any Federal law or regulation or to avoid any transaction reporting requirement

under Federal law or regulation;

(ii) Is designed, whether through structuring or other means, to evade any requirements

of this part or any other regulations promulgated under the Bank Secrecy Act, Public Law 91–

508, as amended, codified at 12 U.S.C. 1829b, 12 U.S.C. 1951–1959, and 31 U.S.C. 5311–5314,

5316–5332;

(iii) Has no business or apparent lawful purpose or is not the sort in which the particular

customer would normally be expected to engage, and the loan or finance company knows of no

reasonable explanation for the transaction after examining the available facts, including the

background and possible purpose of the transaction; or

(iv) Involves use of the loan or finance company to facilitate criminal activity.”

Where to File

All SARs must be filed electronically in accordance with FinCEN’s instructions.

Timing of Filing

All SARs must be filed within 30 days of the initial detection of suspicious activity, unless a

suspect was not identified with the initial detection. In that case, the SAR must be filed no later

than 60 days after initial detection.

Record Retention

All SARS and supporting evidence for the SAR must be maintained for a minimum of five years

from the date of filing.

There are other provisions of the SAR Rule, including those relating to:

• Confidentiality and disclosure notification requirements of SAR reports.

• Filings of reports on currency in excess of $10,000

• Information Sharing

Designated officer of Mazlat inc. is designated as AML compliance officer.

Resources Mazlat, Inc. strongly encourages our associates to review the full SAR Rule as well as some of

the below references:

• SAR Rule

• FinCEN’s website for mortgage lender and brokers

• FinCEN’s BSA E-Filing System

• FFIEC’s BSA/AML Examination Manual

• www.stopfraud.gov

)

18

Advertising & Marketing Submission Form Date of Submission:___________________________ Loan Officer / Agents Name:_________________________________________ Best Contact Phone:________________________________________________ Email Address:____________________________________________________ Which of the following methods of advertising will be used: (Check all that apply) Internet Radio Direct Mail Television Flyers Other Print Advertisement Newspaper Please list the name of the publication where the ad will appear or the website address: Please fax this form along with a sample of the ad to 888-575-3279 or email to rslepack@gmail.com. We will do our best to review ALL advertising within the times estimated below. Turnaround time for Print ad review is 1 to 2 days Turnaround time for Website, Radio or Television ad review is 3 to 4 days

)

19

Predatory Lending Prevention and Zero Tolerance for Loan Fraud

Mazlat, Inc. supports consumers’ right to be treated fairly and honestly, and to be

given equal access, full disclosure, and be subject to an objective evaluation of their

creditworthiness.

As an ethical mortgage broker, we utilize recognized standards including work history, creditworthiness, down payment capacity and debt-to-income ratios to evaluate and process loan applications. We strive to provide consumers with a variety of options based on each consumer’s individual financial situation and long-term goals. Our professional loan originators explain all relevant loan information and give consumers the time necessary to make informed and considered decisions regarding their home financing choices. By contrast, predatory lending practices are based on fraud, deception, coercion and greed. Mazlat, Inc. unconditionally denounces predatory lending practices and has a zero tolerance policy. Violations are cause for immediate dismissal and termination of our contract. Brokers are required to report to the Department of Real Estate any

instance of a salesperson being terminated for a cause. PREDATORY LENDING is intentionally placing consumers in mortgage loans with significantly worse terms and higher costs than loans offered to similarly qualified consumers, by the majority of mortgage brokers or lenders in the region, for the primary purpose of enriching the loan originator and with little or no regard to the costs to the consumer. Refinancings that do not result in an identifiable, tangible benefit to the consumer are prohibited.

Predatory lending is not only unethical, predatory lending practices are often

violations of State and Federal law! Examples include:

• Fraud: Forged loan documents, falsified tax returns or other documents, overstating income or assets to qualify borrowers for loans they cannot afford, inflated appraisals.

• Discrimination: Charging higher rates and fees, with less favorable terms, to borrowers based on their race, national origin, age, marital status or neighborhood, than would be charged according to traditional factors such as employment history, credit record, and sufficient income to make required mortgage payments. Steering borrowers towards interest rates that far exceed the lender’s risks. Requiring high-cost credit insurance (“packing”).

• Misrepresentation: The costs or loan terms at closing are not as advertised, or as presented at the time of application, and which are not properly disclosed prior to closing as mandated by law.

• Bait and Switch: Qualified borrowers are steered away from affordable options for the express purpose of increasing fee income to the unethical loan originator.

)

20

Persuading a borrower to repeatedly refinance a loan in order to charge high points and fees each time the loan is refinanced (“loan flipping”).

• Non-Disclosure: Key costs, fees, and terms are not disclosed, or inaccurately or only partially disclosed in violation of law and State and Federal lending regulations.

To protect consumers from falling victim to predatory lending practices, we

encourage our Associate-Licensees to advise borrowers to:

• Never sign a blank document. • Read all documents carefully and ask questions. Do not be hurried into signing

anything not clearly understood. Stop the entire transaction if you feel you are not getting clear answers.

• Do not be pressured into applying for more money than you can reasonably be expected to pay back according to the terms of your loan.

• Get copies of all loan documents, especially anything you have signed. • Have all fees and points explained to you before applying for a loan. • Make sure that you have received, read and understand all required disclosure

documents. • Check to see if the loan terms quoted to you match your loan documents.

MORTGAGE FRAUD IS INVESTIGATED BY THE FBI

Mortgage Fraud is investigated by the Federal Bureau of Investigation and is punishable by up to 30 years in federal prison or $1,000,000 fine, or both. It is illegal for a person to make any false statement regarding income, assets, debt, or matters of identification, or to willfully overvalue any land or property, in a loan and credit application for the purpose of influencing in any way the action of a financial institution. Some of the applicable Federal criminal statutes which may be charged in connection with Mortgage Fraud include: 18 U.S.C. § 1001 - Statements or entries generally 18 U.S.C. § 1010 - HUD and Federal Housing Administration Transactions 18 U.S.C. § 1014 - Loan and credit applications generally 18 U.S.C. § 1028 - Fraud and related activity in connection with identification documents 18 U.S.C. § 1341 - Frauds and swindles by Mail 18 U.S.C. § 1342 - Fictitious name or address 18 U.S.C. § 1343 - Fraud by wire 18 U.S.C. § 1344 - Bank Fraud 42 U.S.C. § 408(a) - False Social Security Number

훐�

21

Payment to Corporations Mazlat, Inc. as a licensed real estate broker can only compensate a licensed salesperson under its broker’s license or another licensed broker. If a salesperson would like their share of the commission paid to a corporation, the Department of Real Estate has ruled that this can be done by requesting this in writing to the broker, and by having the broker submit written instructions to the escrow company directing it to pay the salesperson’s share of the commission directly to the salesperson’s corporation. This can be easily accomplished by filing out and sending the form on the following page to the broker, who will in turn send it to escrow. The salesperson’s corporation cannot perform acts which require a real estate license. Mazlat, Inc. will submit earnings reports on its salespersons in its tax filings, however it is not required to report payments to corporations. Tax reporting for the salesperson’s corporation is the responsibility of the salesperson. Please use the form on the next page on each transaction you wish to have paid to a corporation instead of having it paid directly to you. A separate request must be written for each transaction. Leave the check amounts blank. The form must be received prior to the close of escrow, and the completed file must be received before your check can be issued, with the exception of final closing documents. Checks and closing packages should be sent directly to the corporate office location unless specific arrangements have been made by broker for pick up. Mazlat, Inc. cannot guarantee that an escrow company will cooperate. If they refuse to pay the salesperson’s share to the requested corporation and will only pay the broker, the broker can then only pay a salesperson, broker, or corporation that is licensed by the Department of Real Estate.

侮�

22

Commission Disbursement Request This Commission Disbursement Request is by and between Mazlat, Inc., dba Primary Benefit Properties and Primary Benefit Lending and _________________________________________________(Independent Contractor). Independent Contractor is requesting that commissions due to Independent Contractor on the following escrow/loan #___________________________________ and the following borrower(s)_________________________________________ be disbursed directly by escrow payable to the following parties:

1) Check made payable to: _________________________________________ Check in the amount of:_________________________________________

2) Check made payable to:_________________________________________ Check in the amount of:__________________________________________

Independent Contractor understands he/she is responsible for any state or federal tax liabilities from the monies paid through this request. Independent Contractor certifies that he/she is either an officer, a shareholder, an employee, or is otherwise affiliated with the corporation to whom the monies are requested to be paid in item #1. Independent Contractor agrees to indemnify, defend and hold Mazlat, Inc. and the escrow company harmless from all claims, losses, expenses, and fees that may be asserted against Independent Contractor as a result of this request and agreement. Agreed this______________________ day of _______________________, __________ ______________________________ _____________________________ Independent Contractor (signature) Officer for Broker (signature) _______________________________ ______________________________ Printed Name Printed Name

检�

23

Compliance/Quality Control Checklist: Real Estate Sale Print a copy of this form as soon as you take a listing or get an accepted offer, and contact

the corporate office within 48 hours.

LISTING: Upon taking a listing please contact the corporate office within 48 hours.

___ C.A.R. Form AD: Disclosure Regarding Real Estate Agency Relationships (seller) (should be signed prior to listing agreement) ___Addendum to Disclosure Regarding Real Estate Agency Relationships (form is in this office policies manual) (should be signed prior to listing agreement) ___ C.A.R. Form RLA: Listing Agreement (Listing contracts must contain a termination date and must disclose the negotiability of commissions.)

___ C.A.R. Form SA: Seller’s Advisory

___ C.A.R. Form AS: Seller’s Affidavit of Non-Foreign Status And/Or California Withholding Exemption-Foreign Investment in Real Property Tax Act (FIRPTA)

___ MLS Printout

SALE: Upon getting an accepted offer please contact the corporate office within 48 hours.

___ C.A.R. Form AD: Disclosure Regarding Real Estate Agency Relationships (buyer and seller) (should be signed prior to purchase contract)

___Addendum to Disclosure Regarding Real Estate Agency Relationships (form is in this office policies manual) (should be signed prior to purchase contract)

___ C.A.R. Form RPA-CA: California Residential Purchase Agreement and Joint Escrow Instructions/ Buyer’s Inspection Advisory (Always use most up to date form) ___ C.A.R Form WPA: Wood Destroying Pest Inspection and Allocation of Cost Addendum

___ Any Addendums, Contingencies, Counter Offers, Supplements, Notices to Perform, and Contingency Removals

裰�

24

___ MLS Printout

DISCLOSURES: (Some forms may be included in disclosures package provided by escrow. If so, some of the additional CAR forms listed here are not needed.)

___ C.A.R. Form TDS Real Estate Transfer Disclosure Statement or C.A.R. Form AVID Agent’s Visual Inspection Disclosure: *The listing agent and the selling agent each have the duty to conduct a reasonably competent and diligent visual inspection of the property and to disclose to a prospective buyer all material facts affecting the value or desirability of the property that an investigation would reveal. If C.A.R. form TDS is not required (foreclosures), use C.A.R form AVID. Agent is still required to conduct inspection, even on foreclosures. ___ C.A.R. Form NHD: Natural Hazard’s Disclosure ___ C.A.R. Form WHSD: Water Heater and Smoke Detector Statement of Compliance ___ C.A.R Form FLD: Lead Based Paint Disclosure ___ Regional and County Disclosures if any ___ Earthquake Safety, Environmental Hazards, Federal Lead Booklet, and Toxic Mold Update Receipt (From back of Combined Hazards Booklet) ___ Residential Earthquake Hazards Report ___ C.A.R. Form SSD: Supplemental Statutory Disclosure ___ Mello Roos Tax Disclosure (if applicable) ___ C.A.R. Form MCA: Market Conditions Advisory ___ C.A.R. Form SBSA: Statewide Buyer and Seller Advisory PLUS Addendum (in this manual) ___ C.A.R. Form SPQ: Seller’s Property Questionnaire ___ Affiliated Business Arrangement and Dual Compensation Disclosure ( if also using Primary Benefit Lending) (form is in this office policies manual) (buyer and seller must sign prior to the close of escrow)

⋰ԝ

25

INSPECTIONS: ___ C.A.R. Form VP: Verification of Property Condition (Buyer’s Final Inspection)

___ Copy of Buyer’s Inspection Report, OR C.A.R Form BIW: Buyer’s Inspection Waiver

___ Delivery of Structural Pest Control Inspection and Certification Reports, and copies of reports, OR C.A.R Form BIW: Buyer’s Inspection Waiver *If a termite inspection is done, the real estate broker acting as agent for the seller in the transaction shall effect delivery of the inspection report, certification and the notice of work completed, if any, to the transferee. Broker must maintain a record of the action taken to effect compliance with DRE regulations and sections of the Civil Code and Business and Professions Code, so this paperwork must be included in the file given to the corporate office.

___ C.A.R Form RR: Requests for Repair and Responses (if any)

ESCROW:

___ Escrow Instructions including copy of deposit check

___ Escrow Closing Statement

___ Preliminary Title Report

___ Commission Instructions

___ Home Warranty (if any)

___ All other documents used in the transaction (include everything)

炰�

26

Compliance/Quality Control Checklist: Mortgage File This form to be turned in with each file. Place checkmark next to items included in file.

Please stack in order for quicker review and payment.

Type of loan(s):_________________________________________________ (Examples: 30 year fixed, 5/1, stated or full doc, VOE only, refi or purchase, etc.)

___ INITIAL 1003 Application *Date of receipt ___/___/____

The next 10 disclosure forms must be given at the time of receipt of application,

and mailed or otherwise delivered to the borrower within the next 3 business

days.

1.___ INITIAL Mortgage Loan Disclosure Statement (MLDS). Please check one loan type:

Traditional_____ (use form RE882) or Non-Traditional______ (use form RE885) __*Must contain amount of all compensation including any anticipated rebates from the lender __*Must contain the broker license identification number and DRE licensing information telephone number __*Must use proper form (Traditional or Non-Traditional) and fill out completely

2. __ INITIAL Good Faith Estimate required by HUD (new 1/2010) __ Loan Originators are prohibited from steering consumers to a lender offering less favorable terms in order to increase originator’s compensation. You must provide safe harbor by presenting loan offers for each type of loan the consumer expresses an interest, and options include the lowest rate for which he qualifies and the lowest amount for points and fees. You must obtain options from a significant number of lenders with whom you normally do business. You must have a good faith belief that options presented are for loans for which consumer likely qualifies. You cannot choose one lender over another based upon earning more compensation. 3.___ INITIAL Federal Truth in Lending Disclosure (TIL) *Must be provided concurrently with the MLDS/GFE form *Adjustable rate loans must contain best and worst case scenarios 4.___ Fair Lending Disclosure Notice

5.___ Equal Credit Opportunity Act Disclosure

8

27

6.___ Privacy Policy Disclosure 7.___ Credit Score Disclosure 8.___ Right to Receive Appraisal 9.___ Mortgage Loan Origination Agreement

10.___ Servicing Disclosure Statement ___ *If a purchase transaction: borrower must also be given a copy of the “Settlement Costs and Information Booklet” within 3 days of their loan application. This is available online at www.hud.gov or the Primary Benefit Corporate office can email you a copy. ___ Credit Report and Supplements *Date of credit report: ___/___/___ ___ Borrower Signature Authorization - signed & dated no later than date credit report was run ___ Verification of Deposit dated within 10 days of funding (this is an internal requirement on any file that requires verified assets as a loan condition) ___ Final 1003 application (any change in loan terms disclosed in a timely manner) ___ Final MLDS/ GFE (required when any initial disclosed fees change, disclose in a timely manner) ___ Final Federal TIL Disclosure (required when any initial disclosed fees change) ___ 1008 Transmittal Summary

___ Lender Loan Submission Sheet ___ Lender Approval and Conditions list ___ Affiliated Business Arrangement and Dual Compensation Disclosure (if also using Primary Benefit Properties) (form is in this office policies manual) (buyer and seller must sign prior to the close of escrow)

潐ԝ

28

___ Lock Request or Confirmation ___ Doc Request ___ Final HUD Settlement Statement ___ Any Initial and Final DU and LP Underwriting Approvals ___ Any Verifications (Mortgage, Rent, Deposits, Employment) ___ Any Bankruptcy or Divorce Documents ___ Income Docs, Asset Verifications (1040s, paystubs, W2s, Bank Statements, etc.) ___ Rental Property Lease Agreements ___ Escrow Instructions ___ Purchase Contracts ___ Preliminary Title Report and Supplements ___ Appraisal Copy with Photos

___ All other documents used in the transaction (include everything)

潐ԝ

29

Affiliated Business Arrangement and Dual Compensation Disclosure

This is to give notice that Primary Benefit Lending and Primary Benefit Properties are owned by the same entity known as Mazlat, Inc. Primary Benefit Lending provides mortgage loan services while Primary Benefit Properties provides real estate services. If you elect to utilize the services of Primary Benefit Lending and/or Primary Benefit Properties, the company and/or agent representing you may benefit separately from each service provided. The cost of services by the above named entities will be determined by agreement with all the parties involved, in accordance with the normal, customary and reasonable practices of the real estate industry and the laws and regulations of the real estate industry and the laws and regulations of the various state and federal regulatory agencies. Set forth below is and estimated charge or range of charges for the following:

Primary Benefit Lending:

Fees are based on the size and type of loan provided and range from 0-4.99% or more of the loan amount. Interest rates fluctuate based on market conditions, the type of loan, and the size of loan. Rates and fees are adjusted often to reflect market conditions and a current quote should be obtained.

Primary Benefit Properties:

Fees are based on the size and type of home purchased or sold and range from 0-8% or more of the home purchase or sales price amount. Market conditions may fluctuate. Rates and fees are adjusted often to reflect market conditions and a current quote should be obtained.

You are under no obligation to use the services of Primary Benefit Lending and Primary Benefit Properties together. You may select a provider of your choice to provide the services offered. You may be able to obtain these services at a lower rate by shopping with other providers.

Mazlat, Inc. hereby discloses that as the broker of record representing one or more parties to this transaction it will also receive or anticipates receiving compensation from securing the loan to finance the transaction. By signing below you acknowledge this, and will ensure that you are provided and will review a copy of the HUD-1 closing statement prior to the close of escrow so that you are aware of the form, source and amount of compensation received or expected. ___________________________________ ______________________________ Property Address Buyer/Seller (circle one) ___________________________________ ______________________________ Date Buyer/Seller (circle one)

潐ԝ

30

Addendum to Disclosure Regarding Real Estate Agency Relationships

Seller's / Buyer's Associate Licensee and Broker agree to exercise due diligence and reasonable efforts to achieve the purpose of the agency relationship. By the signing of this Addendum to the Disclosure Regarding Real Estate Agency Relationships, Buyer / Seller and Associate Licensee and Broker agree that the scope of the Associate Licensee and Broker's representation of the Buyer / Seller is limited by the terms of this Addendum.

Associate Licensee and Broker shall not have the duty or responsibility to perform the following: (1) decide the purchase price of the subject property; (2) guarantee the condition of the subject property; (3) have responsibility or liability for defects that are not known to Associate Licensee or Broker and are not observable by a reasonably diligent visual inspection of accessible areas of the subject property; (4) verify, inspect, guarantee or warrant the repairs performed by or at the instruction of the Seller; (5) identify property boundary lines or verify lot size or square footage; (6) verify inspection reports and representations of others, including, but not limited to termite or pest control inspectors or their clearance, contractors, home inspectors, soils or other engineers, and any other inspections or representations made by others concerning the condition of the subject property; (7) provide legal or tax advice; (8) inspect of areas off the site of the subject property; (9) obtain, review or verify permits; (10) inspect public records concerning the title or use of the subject property; (11) investigate or advise on soil stability, geologic conditions, drainage, hazardous substances, structural conditions of improvements, or the condition of the roof, heating, air conditioning, plumbing, electrical, well, sewer, septic, waste disposal or other systems; (12) provide any advice or information that exceeds the knowledge, education and experience required to obtain a real estate license.

I/WE HAVE READ AND UNDERSTAND THIS ADDENDUM AND ACKNOWLEDGE RECEIPT OF A COPY OF THIS ADDENDUM TO THE DISCLOSURE REGARDING REAL ESTATE AGENCY RELATIONSHIPS.

Buyer / Seller ________________________________ Date __________ Time ________

Buyer / Seller ________________________________ Date __________ Time ________

Agent ______________________ By ______________________ Date ______________ (Print Name) (Associate Licensee or Broker Sign)

潐ԝ

31

ADDENDUM TO THE STATEWIDE BUYER AND SELLER ADVISORY

Property Address_______________________________________________

Real Estate Brokers can only advise on real estate. Real Estate Brokers do not have expertise in areas and

conditions that are set out in the Statewide Buyer and Sellers Advisory (CAR FORM – SBSA) and any

Addenda which may be attached to the advisory.

Upon receiving, reviewing, reading and understanding the Statewide Buyer and Seller Advisory and any

Addenda attached thereto, as well as the Real Estate Transfer Disclosure Statement (CAR FORM – TDS-11), The Buyer(s) have elected to have the following inspections performed on the subject property, as evidenced by Buyer(s) initials: Physical Home Inspection Soil and Geologic Conditions Environmental Hazards

(______) (______) (______) (______) (______) (______)

Septic Systems Well and Water Systems Roof Inspection

(______) (______) (_____) (_____) (______) (______)

Boundary Lines/Lot Size Easements/Encroachments Pool and/or Spa

(_____) (______) (_____) (_____) (_____) (______)

Permits, Zoning & Code Compliance Water Shortages and Conservations

(______) (______) (______) (______)

WAIVER OF INSPECTIONS: In the event Buyer(s) elects to purchase the subject property without

anyor some of the professional inspections stated above, Buyer(s) is acting against the advice and recommendation of the Listing and Selling Brokers.

With respect to such inspections and/or inspection reports not obtained by Buyer(s), Buyer(s) agrees that

Buyer(s) will conduct his/her own independent investigation of the subject property and basis his/her

decision to purchase the subject property on his/her own independent investigation.

NO VERIFICATION OF INFORMATION BY BROKERS: Brokers hereby inform Buyer(s) that

Brokers have not and will not verify any information provided by Seller(s) or any other source.

BUYER(s) HEREBY ACKNOWLEDGES THIS ADDENDUM

Name ____________________________ Signature __________________________________ Date ________

潐ԝ

32

Current List of Approved Lenders (Alphabetically)

Accredited Home Lenders 866-858-LEND Broker #129954 Rep: Michael Maris 888-290-2028 ext 2235 Direct: 714-621-2235 Fax: 866-230-9835 Cel: 951-283-1843 mmaris@accredhome.com www.accredhome.com

At Home Capital

877-222-5569 www.athomecapital.com Rep: Perri Echlin Phone: (800) 640-1537 Fax: (800) 640-1538

Aurora Loan Services

Broker # 24900 Rep: Lisa Poutre Cell: 949-254-1077 Toll free 800-221-1815 lpoutre@alservices.com www.alservices.com

Barkley Funding Int’l Corp.

144 Continente Av. Ste. #220 Brentwood, CA 94513 Phone: 925-809-3160 Fax: 925-809-3177 or 925-634-7937 Reps: John Radecke, 925-570-3833 Or Todd Mendoza, 925-250-5490 Their assistant: Teresa Dominguez, 925-809-3160 Processors: Ana Muniz, 925-809-3178 Or Kathy Roman, 925-809-3170

Bottomline Mortgage, Inc.

ID # 07159 800-820-5626 626-739-5300 Rep: Louis Ysassi Fax: 626-739-5320 lysassi@blmexpress.com www.blmexpress.com

Central Banc Mortgage Corporation

Rep: Craig Aloisio 800-591-8131 310-795-8170 cell 866-640-5050 direct fax craiga@centralbancmtg.com Underwriter: Mark Hemoitt 425-289-2032 x124 Processor: Chelsie Newbold 425-289-2032 x109 www.centralbancmtg.com

Clearvision Funding (updated 9/2011)

800-470-6309 Broker ID: 100558 Rep: Cory Tona 714-380-6984 CTona@clearfundings.com

CMG Mortgage (updated 6/2010)

Broker ID# is 6636-01 Acct Exec: Dave Herbst (858) 583-3745 dherbst@cmgmortgage.com Inside sales: Kristen Shevlin 925.983.3051 kshevlin@cmgmortgage.com www.cmgbanking.com www.homeownershipaccelerator.net

穀�

33

Credit Suisse

Customer ID: 6708 www.credit-suisse.com/connect User ID: mazlatinc Password: Mmaz001 Deal Desk: (877) 273-2321 - option 2 Reps: Joanne Chang 408-515-1212 Carl Le 408-316-9229 Joanne.chang@credit-suisse.com Carl.le@credit-suisse.com

DB Home Lending

26521 Rancho Pkwy South - Ste 210 Lake Forest, CA 92630 Broker ID# 14755 800-416-0614 800-662-2613 Fax Rep: Juju Bundakji 714-585-6369 888-860-9055 Fax juju.bundakji@db-homelending.com www.db-homelending.com

E-Loan, Inc.

6230 Stoneridge Mall Road Pleasanton, California 94588 Rep: Andrew Goett (877) 356-2648 x- 6691 | Toll Free (925) 847-6691 | Phone (925) 520-1801 | Fax Email: andrewg@eloan.com Website: www.eloanwholesale.com

EZ Funding Corporation

17100 Pioneer Blvd. Suite 405 Artesia, CA 90701 Tel: 562-924-9555 Fax: 562-924-9300 Rep: Kevin Hwang www.ezfc.com

First Bank Mortgage

Broker code: 7671 800-400-0044 909-396-4785 Fax Rep: Linda Kelly 714-345-1794 www.firstbankmortgage.net User name: diamondbar Password: shadow

First Cal (First California Mortgage

Company)

Broker ID: 202301 Web Trac Pro password: FFG12$07 Rep: Karen Page (626) 818-8600 cel 866-557-8996 fax kpage@firstcal.net www.firstcalwholesale.net

First Federal Bank of California

Broker # 10478 Rep: Dori Deluchi ddeluchi@firstfedwholesale.com P: 760-219-9711 Loan in process: Mary Luikens : P: 310-665-2359 F: 310-260-8354 Pouran Saeedi: P: 310-665-2353 F: 310-260-4093 www.firstfedca.com

First Fidelity Financial Corp.

949-706-2000 Broker code: PBL070926 Password: FFF2000 Rep: Jamil Atcha ext. 203 Fax 949-706-7145 www.fffbrokers.com

驀�

34

First Mortgage Corp. (updated

11/2011)

Rep: Jennifer Jarvis jjarvis@firstmortgage.com 800-590-5363 Toll Free 408-782-7775 Direct www.fmcwholesale.com

Gateway Mortgage Group

Broker # W50695 Rep: Jerry Lair (817)545-6153 weirdloans@nonprimewholesale.com 918 392 8364 Fax www.gmos.us User ID: w50695 Password: snoopy1

ICON Residential Capital

Broker ID: 15414 Rep: Gary Thompson gthompson@iconrescap.com 949-379-7000 Cel: 949-365-6683 www.iconrescap.com

IMPAC Mortgage (updated 11/2011)

Broker ID: 000930349 Rep: Danna Reyes Danna.Reyes@impaccompanies.com C: 818-669-2009 O: 855-GO-IMPAC www.ImpacWholesale.com

J & R Lending

Broker ID: 1828 877-323-0799 Rep: Luke Manke 818-209-2592 cel 818-333-1863 ofc 818-450-0395 fax luke@jrlend.com www.jrlend.com

Just Mortgage (updated 10-23-2009)

9680 Haven Av. Ste. 200 Ranch Cucamonga, CA 91730 Broker ID: 4789 909-348-1600 Rep: Mitzi Orlanes Cell (626) 277-7725 Fax (626) 737-0673 Mitzi.orlanes@justmtg.com www.justmtg.com

Kinecta Federal Credit Union

(updated 10/2011)

Broker ID:1116 Rep: Khadija Dadabhoy KDadabhoy@kinecta.org 310-643-2111 Office 949-529-8235 Cell 310-536-3609 E-Fax www.LoanKinection.com

Lockheed Federal Credit Union (does

commercial loans)

818-565-2146 Rep: Patrick Zarifian Cel: 818-298-1627 Fax: 818-688-0405 pzarifian@lockheedfcu.org www.lockheedfcu.org

Lydian Mortgage

Broker # 545824-B 866-665-0640 Rep: Scott Blaney Cell: 949-633-6517 scott.blaney@lydianmortgage.com www.lydianmortgage.com

驀�

35

Marblestone Funding Inc.

500 Bollinger Canyon Way A-11 San Ramon, CA 94526 Rep: Karen Mulock Phone: 925-855-8812 Fax: 925-855-8834 email: kmulock@sbcglobal.net

Mega Capital Funding (updated

8/2011)

818-657-2600 Rep: John Cirino JCirino@MCFunding.com

Money USA

Rep: Jackie Richison 888-900-9993 Ext. 110 Fax: 310-837-9554 www.moneyusanow.com

Mortgage Close.com

Broker ID 111642 866-Borrow-1 Rep: Karyna Rhubin 714-453-0220 ext. 218 Fax 714-384-7598 karyna@mortgageclose.com http://B2B.MortgageClose.com

MortgageIT

ID# 206-0303 Password: BROKER Phone: 866-328-6385 Fax: 626-639-1891 Rep: Serineh Cholokian 626-399-5683 scholokian@mortgageit.com Customer Service Rep: Eileen Sugano 626-639-1920 esugano@mortgageit.com www.mitlending.com

Mortgage Solutions of Colorado

(updated 7/2011)

Rep: Mitzi Orlanes 719-447-0325 Mitzi.Orlanes@msofco.com Fax 719-531-3084

National City Mortgage

Rep: Jeffrey Ma Broker code: 655799 Office: 818-386-9800 Cellular: 626-922-8383 Fax: 626-236-9332 Email: jeffrey.ma@earthlink.net www.goncm.com/jeffreyma

Nations Direct (updated 3/2011)

Rep: Martin Warren Phone: 949-270-7962 Fax: 949-270-7641 mwarren@brokerfha.com website - www.brokerfha.com Conditions or Questions on Files: Laura A. Werner - Account Manager (P) 949-270-7966 lwerner@brokerfha.com

NBGI- National Bankers Group, Inc.

323-850-2200 Rep: Hugh Huynh 714-273-0704 hugh@nbgi.com www.nbgi.com Web access user name: nbgi Password: money

驀�

36

Neighborhood Lenders

866-957-1500 Rep: Matt Fisher 925-522-6446 matt@neighborhoodlenders.com www.neighborhoodlenders.com *If using “Contract Delivery” products, check with corporate office to see if salesperson’s corporation can be paid. Commissions are paid directly to broker by lender.

No Red Tape Mortgage/ Zero Down

Mortgage/ Metrocities Mortgage

Rep: Colin Robertson (818) 742-3048 Or 800-300-9017 x3048 (213) 337-1289 FAX Email: colin@noredtape.com www.noredtape.com www.zdmortgage.com

Opteum Financial Services, LLC

888-586-0002 Client ID # 131730000W Rep: Tom Rodzewich ph. 310-482-1066 fx. 866-818-4967 trodzewich@opteum.com www.opteumwholesale.com

Option One Mortgage

949-930-7200 Rep: Anthony Simich 949-289-2919 anthony.simich@oomc.com www.optiononebroker.com Broker # 129956

PacificBanc Mortgage (updated

8/12/10)

Broker approval # 01068748 949-419-0505 Rep: Noshin Khoja Lalani 949-678-8843 noshin@pacificbanc.com www.pacificbanc.com Must use Mazlat, Inc. on 1003s

Pacific City Bank (updated 9/2011)

213-210-2000 Rep: Jae Kim 213-355-8834 Mobile: 323-833-1888 jkim1112@gmail.com

Pacific Residential Financing

3020 Saturn St. Ste. #100 Brea, CA 92821 714-577-7700 office 714-577-7701 fax Rep: Jeremy Ryan 714-482-5734 tel 714-777-3438 tel2 714-494-8098 fax jryan@pacificresidential.com www.pacresfunds.com

Paul Financial

Source code: primary ben Rep: Karen Judd 949-554-5860 Cell 949-223-5289 Fax karen.judd@paulfi.com Lock/status/conditions: 877-300-9700 Team #64 or Kristina Ruys www.paulfi.com

驀�

37

Plaza Home Mortgage

1-866-260-2529 Rep: Chandra Nowaczyk 818-400-8228 Chandra.Nowaczyk@ plazahomemortgage.com www.plazahomemortgage.com

PMAC (updated 10/2011)

800-710-PMAC Broker #B0331813 Rep: Kimberly Soash 818-363-8135 ksoash@pmac.com www.pmac.com Daily rate sheet: http://wholesalerates.pmac.com

PMC Bancorp (updated 10-26-09)

2301 E. Daily Drive Ste 200 Camarillo, Ca 93010 Rep: Shelley Karlowsky Cell (805) 990-8125 E-FAX (805) 421-5350 Shelley.karlowsky@pmcmtg.com 888-794-FUND (3863) toll free Website: www.pmcmtg.com Login id- pmcclient password- pmc8289 Please send all conditions to : camcondition@pmcmtg.com E-Fax submissions to: (800) 597-9945 OR E-MAIL TO: SUBMISSION@PMCMTG.COM FOR STATUS ON LOANS: ROSA GOMEZ AT (626) 410-7510 E-FAX: (805) 299-1850 Rosa.Gomez@pmcmtg.com

PRMG (Paramount Residential

Mortgage Group)

Broker Code: PRMRYB-000 Rep: Annie Gotch 909-841-0626 agotch@prmg.net Files in process: Sandi Brumund 951-278-0000 ext. 255 Fax: 951-278-5630 www.eprmg.net

Provident Bank Mortgage(updated

3/2011)

Rep: Debi Tambellini 949-355-6226 tdebim@aol.com 800-733-3657 www.pbmwholesale.com

Security Mortgage Funding Corp.

Broker ID: 1151 Rep: Linda Studdert-Kelly 714-345-1794 (cell) 714-542-2090 x 108 (office) 714-939-6321 (fax) Linda_Kelly@smfcloans.com www.smfcloans.com ID: smfc Password: YOR1052

Stearns Lending, Inc. 4 Hutton Centre, Suite 500 Santa Ana, CA 92707 Rep: Erin Futterer Cell: (714) 287-6291 Phone: (714) 513-7206 Email: EFutterer@stearns.com Acct. Mgr: Amy perkins (714) 513-6956 aperkins@stearns.com Website: www.stearnswholesale.com

驀�

38

Steward Financial, Inc. 1808 Aston Ave., Suite 230, Carlsbad, CA 92008 Broker ID # 3204 Rep: Julian Barajas Phone: (800) 520-1672 Fax: (800) 520-2176 Email: julian@stewardfinancial.net www.stewardfinancial.net

Suntrust Mortgage

Rep: Melissa O’Brien Direct: (805) 550-6193 Email: Melissa.obrien@suntrust.com Status: Christina Tsang (949) 465-7429 phone (949) 587-2809 fax Locks: Lisa Neilson Fax: (949) 458-7196 Website: www.stmpartners.com

360 Mortgage Group (updated 5/2011)

866-418-6000 Rep: Alexa Ross aross@360mtg.com 805-302-8781

Tower Mortgage and Financial

Services Corp.

Broker ID# 420 877-869-3755 Fax: 301-315-2031 Rep: Daniela Gomes Phone: 301-315-0090 Cell: (301) 315-0090 Email: dgomes@towerb2b.com www.towerb2b.com

United International Mortgage Bank

Approval # 301151 Rep: Chris Theard 310-207-5060 x7189 Cel 310-849-9580 Fax 818-827-4984 chris.theard@unitedinternational.com www.unitedinternational.us

US Bank (updated 6/2010)

Broker code: XHX Rep: Joshua Shold 888-455-5551 Toll Free 612-412-6748 Mobile Joshua.shold@usbank.com www.usbank.com User ID: brokerloans Password: FiveStarService08

Vertice Lending

Broker # E016436 Rep: Cindy Schwartz 714-308-7155 Cynthia.schwartz1@wachovia.com Website user name: E016436 Password: AMN76128 www.verticelending.com

WMC Mortgage

3100 Thornton Avenue Burbank, CA 91504 800-542-6508 Rep: Jason McIlvain Tel 818.736.5375 Fax 800.320.8914 jmcilvain@wmcdirect.com Website: www.wmcmortgage.com

驀�

39

World Mortgage Group 6300 Canoga Ave. Ste. 550 Woodland Hills, CA 91367 Rep: Trevor McCann (877) 226-7369 ext. 3043 (818) 749-4942 cel (866) 332-3903 fax Email: tmccann@wmgmortgage.com Website: www.wmgmortgage.com

Note: If you have a lender you would like us to become approved with, please let us know. Please let us know if you discover any inaccurate lender information.

驀�

40

List of Contacts Business Cards:

RUM Design Rafael Ucros 562-746-7232 rafael@rumdesign.com www.rumdesign.com (You can do your cards here or elsewhere. Rafael also does great property flyers!)

Conference rooms:

www.pbcenters.com www.abcnvirtual.com Choose a location, then call Primary Benefit corporate office for reservations.

Credit Reports: (Corporate office will

set up your account)

Informative Research

Tara French Senior Account Representative Office: 800-473-4633 Ext. 210 Cell: 909-272-6304 Fax: 714-638-3749

Encompass Loan Origination

Software, Ellie Mae, Inc. Sandy Amiri, Senior Account Executive, sandy.amiri@elliemae.com Phone: 818-223-2025 Fax: 818-223-3270 www.elliemae.com

Loan Processing:

Danni Gonzales

951-403-0477 888-388-6019 fax adelagracie@yahoo.com Loan Processing: $395

Orange County Association of

Realtors (OCAR)

25552 La Paz Road Laguna Hills CA 92653 Telephone: (949) 586-6800 Fax: (949) 586-0382 MLS Fax: (949) 859-2278

Primary Benefit Corporate Office:

7700 Irvine Center Dr. Suite 800 Irvine, CA 92618 Rich Slepack rslepack@gmail.com 949-388-1052 direct 714-313-0924 mobile 888-575-3279 fax (not for faxing closed files, call for one time use fax number)

Signs:

RESS Real Estate Signs & Supplies (949) 855-1355 www.ress4signs.com [Must use company design for signs. If you choose a different company to print your signs, call Rafael from RUM Design (see Business Cards) to customize your template which other companies can use.]

Training:

Real estate sales contracts training:

www.car.org Winforms Forms Tutor & Forms Advisor. Or try: www.formtrainers.com

Loan officer training: www.loanofficerschool.com

驀�

41

Transaction Management:

Julie Invidiata

(714) 308-3041 Fax (714) 442-2668 JulieSellsOC@gmail.com $195

驀�

42

Acknowledgement

I have received and read a copy of the Office Policies and Branch Operations manual. Associate-Licensee ________________________________________________ (print name) Signature ________________________________________________________ Date ____________________________________________________________ Please return signed copy of this page to the corporate office.