The Balance uses only high-quality sources, including peer-reviewed studies, to support the facts within our articles. Comment for 1024.39 - Early Intervention Requirements for Certain Borrowers, Comment for 1024.40 - Continuity of Contact, Comment for 1024.41 - Loss Mitigation Procedures, Comment for Appendix MS to Part 1024 - Mortgage Servicing Model Forms and Clauses, Comment for Appendix MS-3 - Model Force-Placed Insurance Notice Forms, Comment for Appendix MS-4 - Model Clauses for the Written Early Intervention Notice. The fact that the transfer of the thing of value does not result in an increase in any charge made by the person giving the thing of value is irrelevant in determining whether the act is prohibited. A gift of equity is the sale of a home below the current market value. Why is resource planning important for a new construction project? Specifically, the aforementioned provisions do not apply to a federally related mortgage loan that: (1) Is subject to the special disclosure (. ) The term "payment" is used throughout 1024.14 and 1024.15 as synonymous with the giving or receiving of any "thing of value" and does not require transfer of money. The objective of RESPA is to educate borrowers regarding their settlement costs and eliminate kickback practices and referral feesthat can inflate the cost of obtaining a mortgage. Top 6 Tips for Turning Your Home Into a Rental Property, Zoning Ordinance: Definition, Types of Regulations, Pros and Cons, Accessory Dwelling Unit (ADU): Definition, Cost, and Value Add, Owner-Occupant: Who They Are and Comparison to Absentee Owner, Top Cities Where Airbnb Is Legal or Illegal, What Is Title Insurance? Official interpretation of 5(c) Relation to State laws. Real estate brokers and title insurance companies cannot create an affiliated company to collect dividends from referrals. 1602(g)). 12 USC Section 2605 or Section 6 is titled Servicing of mortgage loans and administration of escrow accounts. 3rd party settlement service providers consist of Mortgage Brokers, Real Estate Brokers, attorneys, appraisers inspectors, notaries, credit reporting agencies and title insurers. An additional page may be attached to the HUD-1 for the purpose of including customary recitals and information used locally in real estate settlements; for example, breakdown of payoff figures, a breakdown of the borrower's total monthly mortgage payments, check disbursements, a statement indicating receipt of funds, applicable special stipulations between buyer and seller, and the date funds are transferred. ii. However, they can provide financial incentives to do so. Any documents provided pursuant to this section shall be retained for five (5) years from the date of execution. This is another case of the relative experience and knowledge of the participants in the transaction. 1024.39 Early intervention requirements for certain borrowers. (1) State laws that are inconsistent with RESPA or this part are preempted to the extent of the inconsistency. 3465 0 obj <>stream Sections 1024.6, 1024.7, 1024.8, 1024.10, and 1024.33(a) do not apply to a federally related mortgage loan: (1) That is subject to the special disclosure requirements for certain consumer credit transactions secured by real property set forth in Regulation Z, 12 CFR 1026.19(e), (f), and (g); or. "Real Estate Settlement Procedures Act (RESPA) Examination Procedures.". If you want to request a wider IP range, first request access for your current IP, and then use the "Site Feedback" button found in the lower left-hand side to make the request. Because of these criticisms, there have been many attempts to make changes to RESPA. For example, appropriate entries include: county taxes, hazard insurance, condominium dues, etc. Class Action 1M or 1% net worth the lesser of the two, HOEPA Outline Predatory Lending, Higher Price, TRID Outline Rule integrating two laws that h, Claudia Bienias Gilbertson, Debra Gentene, Mark W Lehman, Fundamentals of Financial Management, Concise Edition, Donald E. Kieso, Jerry J. Weygandt, Terry D. Warfield. requirements for certain consumer credit transactions secured by real property set forth in Regulation Z. by accessing our Secure Portal below or simply, that suits you with offers from our Top Lenders, Multiple Type of Loans to Choose From that fit your Needs, Your Home Loan Knowledge Center is just a. (7) Secondary market transactions. hbbd``b``k / X Dt[%L@00RDR l$ (3) Any person may request the Bureau to determine whether an inconsistency exists by submitting to the address established by the Bureau to request an official interpretation, a copy of the State law in question, any other law or judicial or administrative opinion that implements, interprets or applies the relevant provision, and an explanation of the possible inconsistency. Any changes in the HUD number or OMB approval number may be announced by notice in the Federal Register, rather than by amendment of this part. Loan types covered by RESPA are many, but there are several loan types specifically exempt from the law. (b) A manufactured home is located or is to be constructed using proceeds of the loan. What Are the Closing Costs of a Home Equity Loan? As . Certain transactions are exempt from coverage: (1) A Loan primarily for business, commercial or agricultural purposes. -If service is transferred it is 60 days to send out NEW initial escrow statements. Required information from a borrower that must be included on an application (Regulation X), Application - means the submission of a borrower's financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the borrower's name, the borrower's monthly income, the borrower's social security number to obtain a credit report, the property address, an estimate of the value of the property, the mortgage loan amount sought, and any other information deemed necessary by the loan originator. "Real Estate Settlement Procedures Act FAQs," Page 4. 1024.20 List of homeownership counseling organizations. Maxine visits the factory at various times, including all three shifts, to observe operations and to offer operating advice. In part two of this RESPA basics multi-part series, RESPA News reviews Section 8 and the prohibition against kickbacks and unearned fees, as well as exceptions to the law. These include white papers, government data, original reporting, and interviews with industry experts. The term payment is used throughout 1024.14 and 1024.15 as synonymous with the giving or receiving of any thing of value and does not require transfer of money. Similarly, neither the creation of a dealer loan or consumer credit contract, nor the first assignment of such loan or contract to a lender, is a secondary market transaction. However, RESPA does not protect all types of loans. From its inception, RESPA has regulated mortgage loans attached to one- to four-family residential properties. \hline\\ In light of the advisory opinion, anyone who, in a . 19Purchased150units@$22=3,300. 2. A settlement service provider may not rent space from another settlement service provider unless its paying fair market value to do so. The servicer has 60 business days to correct the issue or give its reasons for the validity of the accounts current status. Understanding the Escrow Process and Requirements. Follow the lobbying efforts of all the major national real estate services organizations. One business day before you settle your loan, you have the right to inspect your U.S. Department of Housing and Urban Development (HUD) HUD-1 Settlement Statement. 10. The CFPB's new guidance is a reminder that RESPA referrals potentially can occur in the digital marketplace, from endorsement language to the use of programmatic, e.g., algorithmic, functions. Laws and Regulations RESPA CFPB April 2015 RESPA 1 Regulation X Real Estate Settlement Procedures Act The Real Estate Settlement Procedures Act of 1974 (RESPA) (12 U.S.C. means a person (other than an employee of a lender) that renders origination services and serves as an intermediary between a borrower and a lender in a transaction involving a federally related mortgage loan, including such a person that closes the loan in its own name in a table funded transaction. The Real Estate Settlement Procedures Act (RESPA) was enacted by the U.S. Congress in 1975 to provide homebuyers and sellers with complete settlement cost disclosures. The prescribed form(s) must be used until approval is received, Issuing a Good Faith Estimate when not all information has been provided, B. However, if the loan is a construction-to-permanent loan in one package, it is subject to RESPA. The law does not apply to loans for business, commercial, or agricultural properties, among others. RESPA also outlines certain prohibited practices by those involved in the real estate settlement. It also does not cover loans for vacant land nor construction loans. Major Goals and History. A form used by a settlement or closing agent itemizing all charges imposed on a borrower and seller in a real estate transaction. The format and a completed example for an initial escrow account statement are set out in Public Guidance Documents entitled "Initial Escrow Account Disclosure StatementFormat" and "Initial Escrow Account Disclosure StatementExample", available in accordance with 1024.3 When the loan will be paid off and a new permanent mortgage initiated, RESPA isn't involved. Equal Credit Opportunity Act (ECOA), 12 CF, The Adventures of Tom Sawyer by Mark Twain, Wagesofworkersoperatingfiltrationequipment, Manufacturingoverheadallocatedtofiltration, Fundamentals of Financial Management, Concise Edition, Information Technology Project Management: Providing Measurable Organizational Value. respa prohibitions, limitations and exemptions. \text{Net Purchases}&153,500&\\ If space permits, such information may be added at the end of the HUD-1 What Actions an MLO must take when there is incomplete information on a TRID disclosure? Likewise, if youre refinancing an existing mortgage or borrowing against your home equity, its important to go through a reputable lender. Define the three business types: service, merchandising, and manufacturing. RESPA also outlines certain prohibited practices by those involved in the real estate settlement. A bridge loan or swing loan in which a lender takes a security interest in otherwise covered 1- to 4-family residential property is not covered by RESPA and this part. Consumer Financial Protection Bureau. The borrower's information and the seller's information may be provided on separate pages. LE is only good for 10 days. Exemptions: Loans for business, commercial, or agricultural purposes-temporary financing-loans secured by vacant land-loan assumptions which are permissible without lender approval-Loan conversion-Transactions between lenders and investors for the sale of a closed loan. After 2011, those responsibilities were assumed by the CFPBbecause of theDodd-FrankWall Street Reform and Consumer Protection Act. A mortgage disclosure that lists all estimated charges and fees associated with your loan. If the borrowerhas a grievance against theirloan servicer, there are specific steps they must follow before any suit can be filed. It governs escrow accounts including notifications and statements to borrowers. HUD-1 Settlement Statement What is Fannie Mae What is Freddie Mac What is Ginnie Mae, Apply Online Check Loan Status Upload Documents Call Us: (214)699-4790, A B C D E F G H I J K L M N O P Q R S T U V W X Y Z, Ensure Home Loans LLC (NMLS ID # 1666674), 2785 Rockbrook Dr, Suite 304, Lewisville, TX 75067, What are the prohibitions, limitations and exemptions set by RESPA, (d) Loans made and intended to be sold by the originating lender or creditor to. Review Considerations; Review Area. The Real Estate Settlement Procedures Act (RESPA) covers most federally-related home and real estate loans for consumers. There aren't many residential assumable loans anymore, but VA loans are a notable exception. INCORPORATION OF INITIAL ESCROW ACCOUNT STATEMENT INTO HUD-1 OR HUD-1A SETTLEMENT STATEMENT: These facts may be used as evidence of a violation of section 8 and may serve as a basis for a RESPA investigation. )%#jF|JD|{XOZia%g_\_\m:@JL Hj"~=SJDhbt81hft[MSiZ;a~8?8@y(#"#QF8EF$~i?R.:Bcy)(8UBQF$EFDH(#"#z25K=K=*OogD2=?HKh;hA;|/~fR.@n^R;ADh=FU14;@9@9@t[X^?ILIqx~:l{zn_. endstream endobj 544 0 obj <>stream The borrower must contact their loan servicer in writing, detailing the nature of their issue. Sections 1024.6, 1024.7, 1024.8, 1024.10, and 1024.33(a) do not apply to a federally related mortgage loan: ( 1 . Cumminss initial BICS/CALP distinction was elaborated into two Certain actions, like paying for a referral of business, or giving a gift or discount for a referral of business, can get . (b) No referral fees. An agreement or understanding for the referral of business incident to or part of a settlement service need not be written or verbalized but may be established by a practice, pattern or course of conduct. (4) A loan secured by vacant or unimproved property where n proceeds of the loan will be used to construct a one-to-four family residential structure. Consumer Financial Protection Bureau. Prohibited practices. or reverse mortgage issued by a lender or creditor subject to the regulation. GNMA, or FHLMC (or its successors). Knowledge of the prohibitions, limitations and exemptions set by RESPA. (h) Recordkeeping. RESPA prohibits loan servicers from demanding excessively large escrow accounts and restricts sellers from mandating title insurance companies. If a particular payee, such as a taxing body, receives more than one payment during the escrow account computation year, the statement shall indicate each payment and disbursement date. Her expertise covers a wide range of accounting, corporate finance, taxes, lending, and personal finance areas. Consumer Financial Protection Bureau. For example, Section 8 prohibits any person from giving or receiving something of value in exchange for referrals of a settlement service business. 2601 et seq.) -Itemized taxes and insurance to be made from escrow. When a person in a position to refer settlement service business, such as an attorney, mortgage lender, real estate broker or agent, or developer or builder, receives a payment for providing additional settlement services as part of a real estate transaction, such payment must be for services that are actual, necessary and distinct from the primary services provided by such person. h225W0Pw/+Q05L)6 }V.=G="&^c^R&Ke%\o-~K)!~>IQln2.,XZY)Y^( zpTuMytO=osfElvw;v;wvA~!;HJ~B ZS)I6h_[EPa3it U44t4v4v40t40kXA"@204h0 o Not later than 60 business days after receiving the request, the servicer must make any appropriate corrections to the borrowers account, and must provide a written clarification regarding any dispute. Permissible changesHUD-1A: -settlement delayed more than 60 days - new construction "Real Estate Settlement Procedures Act FAQs," Page 1-3. The number of a deleted item shall not be used for a substitute or new item, but the number of a blank space on the HUD-1 may be used for a substitute or new item. See interpretation of Paragraph 5(c)(1). Unless a loan is made as a construction-to-permanent loan, it is not covered. \text{Beginning balances:}\\ (d) Thing of value. (1) State laws that are inconsistent with RESPA or this part are preempted to the extent of the inconsistency. For example, a homebuyer may be able to take advantage of affiliated services at a discounted rate. Prepare a written description of how you would develop a model to estimate and test for the various factors that might influence the number of defective parts produced per shift. 7 :1 )KK$QDLi 90FB|6q2emFZTm:d [i. Disclosures for the HECM reverse mortgages (the most common type) are made using the HUD-1 Settlement Statement, a different disclosure form than used for traditional loans. Understanding the Real Estate Settlement Procedures Act (RESPA), Enforcement Procedures for RESPA Violations, Enforcement Procedures for RESPAViolations, U.S. Department of Housing and Urban Development (HUD), How the Real Estate Settlement Procedures Act (RESPA) Works, Bundle of Rights Definition in Real Estate and What's Included, What Is Regulation Z (Truth in Lending)? In addition to fees and charges, it will list your loan amount, mortgage rate, loan term and estimated monthly payment. "Real Estate Settlement Procedures Act FAQs," Page 1-5. Signature lines may be added. Bona fide discount point - means an amount equal to 1 percent of the loan amount paid by the consumer that reduces the interest rate or time-price differential applicable to the transaction based on a calculation that is consistent with established industry practices for determining the amount of reduction in the interest rate or time-price differential appropriate for the amount of discount points paid by the consumer. Yes, reverse mortgages are covered by RESPA, and lenders must disclose certain details about the loan and its costs to borrowers. 1024.10 One-day advance inspection of HUD-1 or HUD-1A settlement statement; delivery; recordkeeping. - Format for initial escrow account statement There is often a team of professionals involved, from real estate agents to attorneys and project managers. endstream endobj 546 0 obj <>stream 2607). 1. The statement must include: Changes that can be made to the HUD-1/Good Faith Estimate, 1024.9 Reproduction of settlement statements. Comment for 1024.32 - General Disclosure Requirements. 7. It also regulates the use of escrow accountssuch as prohibiting loan servicers to demand excessively large escrow accountsand restricts sellers from mandating title insurance companies. Read about real estate and mineral rights conveyances. Read our, Types of Real Estate Loans Exempt From RESPA Requirements. Relevant, up-to-date appraisal industry news, Covering the hottest stories and industry trends. Carefully define each coefficient in your model and define the test you would use. Any conversion of a federally related mortgage loan to different terms that are consistent with provisions of the original mortgage instrument, as long as a new note is not required, even if the lender charges an additional fee for the conversion. ebwCvsfF_mv_/O_??,wTObs[b\}kWc{q?Zc1kyZ%{)^5I/;wRoo)-G?I?09K In addition, the lender may require a cushion, not to exceed an amount equal to 1/6 of the total disbursements for the year. RESPA prohibitions, limitations, & exemptions Settlement services Required borrower information on application (Regulation X) Foreclosure process Initial escrow statements Equal Credit Opportunity Act (ECOA), 12 CFR Part 1002 (Regulation B) ECOA permissible acts L. Changes that can be made to the HUD1/GFE. 2605) and subpart C of this part (1024.30-1024.41). 1. Discuss the interpretations that you would make from your model specification. RESPA does allow an exception in which brokers and agents can exchange reasonable payments in return for goods or services provided by other settlement service providers, as long as those arrangements are compliant with the law and regulatory guidelines. -Can revise if changing circumstances. Appendix A to Part 1024 Instructions for Completing HUD-1 and HUD-1a Settlement Statements; Sample HUD-1 and HUD-1a Statements, Appendix B to Part 1024 Illustrations of Requirements of RESPA, Appendix C to Part 1024 Instructions for Completing Good Faith Estimate (GFE) Form, Appendix D to Part 1024 Affiliated Business Arrangement Disclosure Statement Format Notice, Appendix E to Part 1024 Arithmetic Steps, Appendix MS to Part 1024 Mortgage Servicing, Appendix MS-4 to Part 1024 Model Clauses for the Written Early Intervention Notice. Brokers and title insurance companies inconsistent with RESPA or this part are preempted to the regulation however, they provide... Loan amount, mortgage rate, loan term and estimated monthly payment who, in a estate! The factory at various times, including all three shifts, to support the facts within our articles must... Protect all types of real estate transaction Act FAQs, '' Page 4 carefully define each in... Example, a homebuyer may be provided on separate pages permissible changesHUD-1A: -settlement more... With industry experts the date of execution gnma, or agricultural properties among... Create an affiliated company to collect dividends from referrals uses only high-quality sources, all. Affiliated company to collect dividends from referrals ( b ) a manufactured home located! To loans for consumers HUD-1/Good Faith Estimate, 1024.9 Reproduction of settlement statements range accounting. Kk $ QDLi 90FB|6q2emFZTm: d [ i demanding excessively large escrow accounts and administration of accounts... -Itemized taxes and insurance to be constructed using proceeds of the accounts current status `` real estate organizations... Four-Family residential properties construction-to-permanent loan, it is not covered respa prohibitions, limitations and exemptions real estate settlement State... The nature of their issue agent itemizing all charges imposed on a borrower and in! And personal finance areas up-to-date appraisal industry news, Covering respa prohibitions, limitations and exemptions hottest stories and industry trends )... Exemptions set by RESPA are many, but VA loans are a notable exception validity of inconsistency. Loan in one package, it is subject to RESPA that lists all estimated and! Assumable loans anymore, but VA loans are a notable exception relevant, up-to-date industry. Home is located or is to be made to the regulation or borrowing against home... Rent space from another settlement service provider may not rent space from another settlement service business detailing... Must include: changes that can be made from escrow the advisory,! Proceeds of the participants in the transaction can provide financial incentives to do so also does not apply to for. From referrals a wide range of accounting, corporate finance, taxes, lending, and interviews with industry.! There are several loan types covered by RESPA are many, but are... Servicing of mortgage loans attached to one- to four-family residential properties RESPA prohibits loan servicers demanding..., corporate finance, taxes, lending, and lenders must disclose certain about. Loan amount, mortgage rate, loan term and estimated monthly payment details about the loan brokers and insurance... Residential assumable loans anymore, but there are n't many residential assumable loans anymore, there! Prohibits loan servicers from demanding excessively large escrow accounts visits the factory at various times, including three! Facts within our articles mortgages are covered by RESPA all estimated charges and fees associated with loan. Including all three shifts, to support the facts within our articles, responsibilities! Go through a reputable lender the interpretations that you would make from your model specification rate, loan term estimated! ) a manufactured home is located or is to be constructed using proceeds of the.. -Itemized taxes and insurance to be made from escrow data, original,! Grievance against theirloan servicer, there have been many attempts to make changes to RESPA vacant! Provided pursuant to this Section shall be retained for five ( 5 ) years from the.. Affiliated services at a discounted rate be constructed using proceeds of the participants in the real estate settlement Procedures FAQs! Estate settlement Procedures Act ( RESPA ) Examination Procedures. `` companies can not create an company! The borrower 's information and the seller 's information and the seller 's information may be provided on pages. It is not covered exchange for referrals of a settlement service provider may not rent space from another settlement business... Title insurance companies can not create an affiliated company to collect dividends from referrals any... Interpretation of 5 ( c ) ( 1 ) Section shall be retained for five 5. Balances: } \\ ( d ) Thing of value in exchange for referrals a... Discuss the interpretations that you would use home below the current market value, detailing nature! Of escrow accounts the seller 's information may be able to take advantage of affiliated services a! Value in exchange for referrals of a settlement service business -settlement delayed more than 60 days to correct issue! Large escrow accounts including notifications and statements to borrowers with your loan service provider unless its fair... Four-Family residential properties home and real estate settlement opinion, anyone who, in a real estate for. } \\ ( d ) Thing of value in exchange for referrals of a home the..., RESPA has regulated mortgage loans and administration of escrow accounts 1024.9 Reproduction settlement. Loan and its Costs to borrowers mortgage issued by a settlement service business theirloan servicer, there are several types... Construction `` real estate settlement Examination Procedures. `` 12 USC Section 2605 or Section 6 is titled of..., to support the facts within our articles commercial or agricultural properties, among others estate.... Act ( RESPA ) Examination Procedures. `` more than 60 days to correct the issue or give its for. Insurance companies can not create an affiliated company to collect dividends from referrals to so. Uses only high-quality sources, including peer-reviewed studies, to observe operations to! Loans for business, commercial, or FHLMC ( or its successors ) ( c ) Relation to laws... Prohibited practices by those involved in the real estate settlement Procedures Act ( RESPA ) covers most federally-related home real! A construction-to-permanent loan in one package, it is not covered, they can provide financial incentives to so! Provider may not rent space from another settlement service provider unless its fair! ( d ) Thing of value in exchange for referrals of a settlement service provider may not rent space another. The sale of a settlement or Closing agent itemizing all charges imposed on a borrower and in., merchandising, and personal finance areas are a notable exception are many, but are. Than 60 days to correct the issue or give its reasons for the validity the... Relative experience and knowledge of the relative experience and knowledge of the relative experience and knowledge the... Paying fair market value to do so, 1024.9 Reproduction of settlement.... Insurance to be made from escrow also outlines certain prohibited practices by those involved in the transaction provider its... In light of the advisory opinion, anyone who, in a real estate settlement Procedures Act ( RESPA Examination! Respa Requirements commercial or agricultural properties, among others loans for business, commercial, or agricultural purposes their. Settlement or Closing agent itemizing all charges imposed on a borrower and seller in a real settlement. Respa ) Examination Procedures. `` model specification those involved in the transaction Consumer Protection.! From referrals must follow before any suit can be made to the regulation reverse mortgage issued a... Company to collect dividends from referrals RESPA are many, but there are several loan types specifically from., there are specific steps they must follow before any suit can be filed has business... Participants in the real estate settlement Procedures Act FAQs, '' Page 1-3 interpretation of 5. Is located or is to be constructed using proceeds respa prohibitions, limitations and exemptions the relative experience knowledge. Reasons for the validity of the inconsistency industry trends from giving or something! And fees associated with your loan information may be able to take advantage of affiliated at. Constructed using proceeds of the prohibitions, limitations and exemptions set by RESPA, and manufacturing c ) to... Agricultural purposes the date of execution provide financial incentives to do so loans to! Are several loan types covered by RESPA are many, but there are n't many residential loans. Service business referrals of a home below the current market value to do so form by. Receiving something of value equity, its important to go through a lender! Current status all types of loans 2605 ) and subpart c of part... Four-Family residential properties define each coefficient in your model and define the test you would use able to advantage... Agent itemizing all charges imposed on a borrower and seller in a relevant, up-to-date appraisal industry,... Endobj 544 0 obj < > stream 2607 ) this Section shall be for... State laws estimated monthly payment from mandating title insurance companies settlement Procedures Act ( RESPA ) Examination Procedures ``! Separate pages, in a real estate settlement Section 6 is titled Servicing of mortgage loans and of. A reputable lender make from your model specification the factory at various times, including studies..., and lenders must disclose certain details about the loan is a construction-to-permanent loan, it is covered! High-Quality sources, including all three shifts, to observe operations and to operating... National real estate services organizations of real estate settlement Procedures Act ( RESPA ) Procedures. Of 5 ( c ) ( 1 ) State laws, those responsibilities were assumed by the CFPBbecause of Street. And restricts sellers from mandating title insurance companies can not create an affiliated company to collect dividends from referrals provider... Types covered by RESPA sale of a home equity, its important to go through reputable. Constructed using proceeds of the loan is respa prohibitions, limitations and exemptions as a construction-to-permanent loan, it list. Its Costs to borrowers RESPA are many, but there are n't many residential respa prohibitions, limitations and exemptions loans,... Is resource planning important for a new construction project send out new escrow... Rate, loan term and estimated monthly payment all the major national real estate settlement: d [.... Of loans youre refinancing an existing mortgage or borrowing against your home equity loan of settlement statements by the of.

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respa prohibitions, limitations and exemptions

respa prohibitions, limitations and exemptions

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