In that case the borrower is not leaving debt, the heirs are accepting debt. In this country, no one can force an heir to accept an inheritance, period. It is not the borrower who is leaving the debt; it is the heirs who have decided to accept the debt as part of obtaining the underlying property.

When property is purchased for more than its market value, the transaction is not a tax reportable transaction unless there is a personal gift, charitable gift, or compensation element in the excess price. Here on the surface none of those elements appear to exist so it would be a nonreportable event for income tax purposes as to the mortgagor/heir.

I do not understand your point. Please expand it.

Be prepared. Not every violation will result in an open statement against the violator or the violation. In other cases, it may end up like the lender who used a tax-exempt to market loans. In that case a state official publicly announced the violation, the violator, and the agreement and it was reported in the newspapers. It was also reported by RMD months ago.

There is little question that marketing must be upgraded and improved. Hopefully, we will see more improvement with time.

I just went to your website and you are still advertising loan proceeds as “tax-free”. Will you please adjust your own website? (“Q4. Does the IRS consider the monthly advances from the reverse mortgage income? A. No, the cash advances are actually loan distributions and are not considered income. The cash advances are tax-free.”)

Someone mentioned you were in the meeting discussed above. I heard the panel had real problems with the phrase “tax-free” and discussed it in particular.

Besides the title of the signer, what else was wrong with the mail piece you are so bothered by? If the name of the lender was displayed, the product was clearly identified as a mortgage, and other things were in order, what is the problem with using an actual title? Perhaps those with such titles should be restricted from signing marketing pieces using those titles but what rule currently prohibits it? Is that really the only thing wrong with the mailing piece? After hearing the comments from the NRMLA session I personally consider declaring proceeds to be “tax-free” on a website far worse.

Not that many of us have your email address. Now that you have attacked all of the top ten retailers (including your former employer), why not just say which entity did this really terrible thing? If it was really that terrible why not send it to the HUD OIG rather than the HUD Office of RESPA or some office in the Florida state government that may have absolutely no authority in such matters, especially if the entity was a nationally chartered bank? Did you send it to NRMLA and/or the FTC? Apparently not. I guess you did not attend the NRMLA Policy Conference or earlier conferences where this subject was discussed.

Do you really believe this one marketing piece should cause one of the top ten retailers to be displaced or held back from advancing in the endorsement pool? Most of the loans that moved that lender up the endorsement list were probably originated before July.

False advertising is awful and should be severely fined — with habitual violators removed from the industry and criminal charges pursued whenever the situation calls for it. But violations including your own should be handled according to the scale of the violation, not according to your idea of what a violation might be.

I just went to your website and you are still advertising loan proceeds as “tax-free”. Will you please adjust your own website? (“Q4. Does the IRS consider the monthly advances from the reverse mortgage income? A. No, the cash advances are actually loan distributions and are not considered income. The cash advances are tax-free.”)

Someone mentioned you were in the meeting discussed above. I heard the panel had real problems with the phrase “tax-free” and discussed it in particular.

Besides the title of the signer, what else was wrong with the mail piece you are so bothered by? If the name of the lender was displayed, the product was clearly identified as a mortgage, and other things were in order, what is the problem with using an actual title? Perhaps those with such titles should be restricted from signing marketing pieces using those titles but what rule currently prohibits it? Is that really the only thing wrong with the mailing piece? After hearing the comments from the NRMLA session I personally consider declaring proceeds to be “tax-free,” far worse.

Not that many of us have your email address. Now that you have attacked all of the top ten retailers (including your former employer), why not just say which entity did this really terrible thing? If it was really that terrible why not send it to the HUD OIG rather than the HUD Office of RESPA or some office in the Florida state government that may have absolutely no authority in such matters, especially if the entity was a nationally chartered bank? Did you send it to NRMLA and/or the FTC? Apparently not. I guess you did not attend the NRMLA Policy Conference or earlier conferences where this subject was discussed.

Do you really believe this one marketing piece should cause one of the top ten retailers to be displaced or held back from advancing in the endorsement pool? Most of the loans that moved that lender up the endorsement list were probably originated before July.

False advertising is awful and should be severely fined — with habitual violators removed from the industry and criminal charges pursued whenever the situation calls for it. But violations including your own should be handled according to the scale of the violation, not according to your idea of what a violation might be.