SPML/LMC anyone claimed for mis selling and unfair charges?

[freedomofspeech]

There are rumours that Amany Attia is no longer a director of SPML, and that CH have not been notified yet. Can anyone help with this

[sawyer]

Please help. I have a first charge with spml and also have a second charge with sppl. I have a warrant for eviction for 15 April by spml. i went to court yesterday and because of the discrepancy on the balance of arrears the judge has adjourned it. The solicitors letter stating that they were applying for a date and also the eviction notice is for spml but when we went to court it was Capstone versus ourselves - thought they were just for administration - if they granted repossession would that mean that it would be Capstone that had the rights to my home, although they are not allowed to hold customers money? Really do not know legalities of this but lady in court suggested we do not go back to court because we will face extortinate solicitors fees and it will drag out, she said to come to an arrangement with Capstone before the court date, but they are not prepared to accept any offer i put to them without a lump sum of a few thousand pound, which i simply do not have. Can somebody please give me advice, have been evicted by sppl once in september 2008 then they let me back in - long story. Now i have it with sml. Just need some advice, nobody, even the judge is not aware of Capstone, solicitor for spml just said it was sister company and he accepted it.

 

Hi WAL, Welcome, no doubt somebody will be along soon to help you. We've all been there ! Interesting Capstone in court. What was the name on the court papers ?

[enoughisenough]

Hi WAL, Welcome, no doubt somebody will be along soon to help you. We've all been there ! Interesting Capstone in court. What was the name on the court papers ?

 

Now let me guess..

 

It would either be SPML, SPPL, London or Preferred...

 

Criminal Fraud disguising itself as the 'wronged party' for the benefit of our gullible District Judges.

 

Freedom of Speech. This is a very interesting development. Can you possibly spill where you are getting the rumours from. (If you can say that is...)

 

Of course we could punt this out to CH and let them do the leg work...

[scedminc]

There are rumours that Amany Attia is no longer a director of SPML, and that CH have not been notified yet. Can anyone help with this

 

Hi Freedom,

 

Rumours?? Any chance of revealing anymore than this. By PM if its not able to be mentioned on open?

 

I have something going on and if I can get this confirmed then it will me and in turn help everyone else enormously.

 

Sced

[actionnotwords]

WAL

Your post is difficult to understand.You must make it crystal clear what the current status is.Forget the lady in the court you are fighting for your home and the court can make a decision and a repayment plan in your favour if your case is properly presented.All I can assume is that you have not kept to a suspended possession order and spml have sought eviction as a consequence,you have contested this based on the true arrears figure and that the judge has adjourned pending clarification from capstone.

Once the status of your case is clarified we can then deal with capstone.

[actionnotwords]

The following spv prospectus has been bought to my attention it contains many if not all of the answers to the current topic of debate ,that is: the authorisation of capstone.

http://www.ise.ie/debt_documents/Eurosail-UK%202007-4BL%20PLC_15.08.07_9352.pdf

 

The following is evident.

1)Capstone receive authorisation directly from the spv via the Mortgage Administration Agreement and have to report regularly to the spv on the condition of the mortgage pool.

2)Enforcement procedure is carried out by Capstone on behalf of the spv

3)The spv through Capstone completely controls the mortgage pool the Lender has no input.

From this key and vitally important document and I would assume all such prospectuses are the same it is quite clear that once the loan has been originated and the beneficial title sold to the spv it is controlled by them through capstone who have no authorisation from the lender and legal titleholder to act in their name.

 

This extract from the prospectus is significant.The Issuer is the spv.

 

Reliance on third parties in relation to the Loans

1)The Issuer has engaged Capstone as the Mortgage Administrator and the Cash/Bond Administrator to administer the Mortgage Pool pursuant to the Mortgage Administration Agreement and to provide certain cash

management services under the Cash/Bond Administration Agreement. It is anticipated that Capstone will delegate certain of its duties as Mortgage Administrator to Vertex and to Lightfoots and certain of its duties as Cash/Bond Administrator to Wells Fargo. In the event that any of the above parties fail to perform their obligations under the respective agreements to which they are a party, Instrumentholders may be adversely affected.

 

2)The rights of the Issuer and the Trustee may be or become subject to the direct rights of the Borrowers against the relevant Legal Titleholder. Such rights may include the right of a Borrower to redeem its Loan and related Collateral Security by repaying his Loan directly to the relevant Legal Titleholder. These rights may result in the Issuer receiving less monies than anticipated from the Loans.

 

3)For so long as neither the Issuer nor the Trustee has obtained legal title, each relevant Legal Titleholder will, pursuant to the terms of the Mortgage Sale Agreement, undertake for the benefit of the Issuer and the Trustee that it will lend its name to, and take such other steps as may reasonably be required by the Issuer or the Trustee in relation to, any legal proceedings in respect of the Loans originated or acquired by it and their related Collateral Security.

 

You will note from 3) above the legal titleholder in this case your original lender is obligated pursuant to the Mortgage Sale Agreement to undertake legal proceedings on behalf of the spv if appropriate.There is no agreement or clause that Capstone be authorised by the legal titleholder to fulfil this obligation fairly conclusive evidence I believe that capstone have no agreement with or authorisation by the legal titleholder as this clause would be an irrelevance.

I will post the relevant sections seperately to make for easier digestion.

Edited March 27, 2010 by actionnotwords

[actionnotwords]

This section deals with the role of Capstone,note again it is under agreement with the spv and not the legal titleholder/lender.

 

 

Administration of the Mortgage Pool

The Mortgage Administrator will be appointed by the Issuer and the Trustee to administer the Mortgage Pool on behalf of the Issuer under the Mortgage Administration Agreement. The duties of the Mortgage Administrator

include:

(a) collecting payments on the Loans and discharging Mortgages and other Collateral Security upon

redemption;

(b) monitoring and, where appropriate, pursuing arrears and enforcing the Collateral Security;

© taking all reasonable steps to ensure safe custody of all title deeds and documents in respect of the Loans and their Collateral Security which are in its possession; and

(d) making claims under insurance contracts (including the Building Policies and the Life Policies (if any)).

The Mortgage Administrator shall exercise such discretion as is vested in it under the Mortgage Administration Agreement for the purpose of administering the Mortgage Pool as would be exercised by a reasonable and

prudent provider of services such as the services to be provided by the Mortgage Administrator under the Mortgage Administration Agreement and each of the other Transaction Documents to which the Mortgage

Administrator is a party. The Mortgage Administrator has no power or discretion under the terms of the Mortgage Administration Agreement to convert a Loan of one type (for example an Interest Only Loan) into a Loan of a different type.

The Mortgage Administrator will be entitled to charge a fee for its services under the Mortgage Administration Agreement, payable on each Interest Payment Date (subject to the Priority of Payments).

The appointment of Capstone as Mortgage Administrator may be terminated by the Issuer (with the consent of the Trustee) or the Trustee on the happening of certain events, including but not limited to:

(a) insolvency or similar events occur in relation to Capstone; or

(b) Capstone is in default under the Mortgage Administration Agreement.

Following any such termination, the Standby Mortgage Administrator will assume this function under the terms of the Mortgage Administration Agreement.

Under the terms of the Delegation Agreements, Capstone will delegate certain of its duties under the Mortgage Administration Agreement to Vertex and Lightfoots.

The appointment of the Standby Mortgage Administrator under the Mortgage Administration Agreement may only be terminated by the Standby Mortgage Administrator by giving not less than 90 days’ written notice to the

Trustee, Capstone as Mortgage Administrator and the Issuer upon the occurrence of certain events relating to the fees of the Standby Mortgage Administrator.

For the purpose of the administration of the Mortgage Pool, the Cash/Bond Administrator will be authorised to operate the Bank Accounts for the purpose of the Cash/Bond Administration Agreement. The duties of the Cash/Bond Administrator will include, inter alia:

(a) managing the operation of the Liquidity Facility and the Bank Accounts;

(b) making the required Ledger entries;

© maintaining and/or replenishing the Reserve Fund; and

(d) operating the Priority of Payments and making arrangements for the payment by the Issuer of interest and principal in respect of the Notes, subject to the terms thereof and to the availability of funds.

The Cash/Bond Administrator will be entitled to charge a fee for its services under the Cash/Bond Administration Agreement, payable on each Interest Payment Date (subject to the Priority of Payments).

The appointment of Capstone as Cash/Bond Administrator may be terminated by the Issuer (with the consent of the Trustee) or the Trustee upon the happening of certain events, including but not limited to certain events of

default or if insolvency or similar events occur in relation to Capstone. Following any such termination, the

Standby Cash/Bond Administrator will assume this function under the terms of the Cash/Bond Administration Agreement.

Under the terms of the Wells Fargo Delegation Agreement, Capstone will delegate certain of its duties under the Cash/Bond Administration Agreement to Wells Fargo.

 

1)In bold relevant sections,again the authorisation to pursue arrears and enforcing security for the loan is given to Capstone by the Issuer not the lender.

2)Capstone is prevented from modifying the loan by its agreement with the issuer to interest only for example,yet more evidence that the spv is controlling the mortgage pool directly and in contravention of FSA guidelines.

 

I BELIEVE THAT THIS PROSPECTUS CONTAINS ALL THE EVIDENCE REQUIRED TO MOUNT A LEGAL CHALLENGE TO THE ROLE OF CAPSTONE IN CURRENT LITIGATION AND CAN POST MORE IF REQUIRED.

Edited March 27, 2010 by actionnotwords

[iconoclash]

Hi - so do you think that capitalising arrears comes under: modifying the agreement?

also, that bit about "lending its name to any legal proceedings", sounds like a kind of deception - surely this is not allowed?

Edited March 27, 2010 by iconoclash
extra query - sorry

[actionnotwords]

An interesting question as in effect the loan has been increased however the terms have remained the same.

It would have to be on the authorisation of the lender and yet capstone takes its instruction from the spv who would have no power to increase the size of the loan which would be secured by the legal charge.

Has capitilisation been offered or performed by capstone?

A fundamental change would be conversion to interest only from a repayment loan which capstone are prevented from undertaking on the instruction of the spv note NOT the lender.

 

also, that bit about "lending its name to any legal proceedings", sounds like a kind of deception - surely this is not allowed?quote campari2

Its a deliberate ploy by the spv to conceal its identity and control of the mortgage it hides behind the lender who is a shell,if capstone had a fully authorised agreement with the lender to stand in its shoes such a clause would be wholly uneccessary,this is the evidence that they simply haven't.

Edited March 27, 2010 by actionnotwords

[iconoclash]

ANW: this is a tricky one and why i keep trying to understand the relationships re SPPL and SPML: we had a secured loan with SPPL which was converted into a mortgage with SPML and increased into higher sum but was taken as NEW business in terms of the mortgage, since we had the secured loan it was stated that we did not need to 'jump through the hoops' re the mortgage as they already had second charge it was thus converted to a first charge - i am still chasing capstone for all the papers and it is with the ICO -so at present i dont know how this was performed or if there was a valuation etc - I see in the info you posted that they accept drive-by's so maybe that was it, I know we paid a lot of fees.

 

Further, the arrears capitalisation I refer to is another company but a similar deal re securitisation:- having remortgaged again (on bad advice) our current lender is the one I refer to being Oakwood Home Loans, bought from GMAC. (trying to get FSA to recognise my OHL contract is still GMAC being administered by OHL and thus the fines scenario should apply to them). Hope this doesnt muddy the water - I do have threads on these elsewhere. Thanks.

[actionnotwords]

So by taking out a mortgage with spml the secured loan to sppl was paid off by spml and spml registered a first charge on the property.(both companies are seperate legal entities)?

[iconoclash]

Hi - yes it seems that SPPL charged me a redemption fee plus an erc plus some other charges and sent this redemption statement on SPPL letterhead from SPML House, Mendy Street, High Wycombe - I presume the end figure was added to the mortgage by SPML but still waiting for data on the mortgage. The solicitors used were Wilson, Cowie & Dillon Law, Liverpool. That must be theirs too.

[not another b----- letter]

ANW: this is a tricky one and why i keep trying to understand the relationships re SPPL and SPML: we had a secured loan with SPPL which was converted into a mortgage with SPML and increased into higher sum but was taken as NEW business in terms of the mortgage, since we had the secured loan it was stated that we did not need to 'jump through the hoops' re the mortgage as they already had second charge it was thus converted to a first charge - i am still chasing capstone for all the papers and it is with the ICO -so at present i dont know how this was performed or if there was a valuation etc - I see in the info you posted that they accept drive-by's so maybe that was it, I know we paid a lot of fees.

 

campari2

 

SPPL only hold (or should that be once held?) an OFT licence for second charge lending up to 25K and regulated by the Consumer Credit Act, for first charge lending and loans over 25K you need to be licenced by the FSA and SPPL are not but SPML are, hence the transfer, what was the date of the transaction?, I don't want the day and the month just the year will be fine, whats going to be very interesting is the paperwork, SPML hold an FSA and OFT licence so you need to have a good look at the way this switch was done, could it have done for less? as both are in the same stable, you never know you might find a loophole?.

 

nabl

[eagleforms]

I have a loan that was originally £36k with SPPL. How does that work?

[Suetonius]

campari2

 

SPPL only hold (or should that be once held?) an OFT licence for second charge lending up to 25K and regulated by the Consumer Credit Act, for first charge lending and loans over 25K you need to be licenced by the FSA and SPPL are not but SPML are, hence the transfer, what was the date of the transaction?, I don't want the day and the month just the year will be fine, whats going to be very interesting is the paperwork, SPML hold an FSA and OFT licence so you need to have a good look at the way this switch was done, could it have done for less? as both are in the same stable, you never know you might find a loophole?.

 

nabl

 

I have a loan that was originally £36k with SPPL. How does that work?

 

Hello Eagle

 

The FSA started to regulate mortgages on 31 October 2004. However, this regulation was limited to first charge loans.

 

If you have/had a second charge loan for more than £25k, provided before the removal of the £25k limit by the CCA 2006, you had an unregulated agreement.

[actionnotwords]

sppl must have been able to grant first charge mortgages otherwise the notices to noteholders concerning transfer of the legal titles in the case of the iminent insolvency of sppl would not have been necessary.Perhaps sppl never received a licence for such loans in which case they could quite possibly be unenforceable or alternatively they were channelled through spml possibly by assignment if they were above a certain level.The appropriate spv prospectus would need to be checked here.The one posted above shows in the transaction structure sppl loans being sold by sppl to spml and then to the spv.Full text below but please see the prospectus link for a clearer picture.http://www.ise.ie/debt_documents/Eur...08.07_9352.pdf

(page eight)

1. THE PARTIES

Issuer, Sellers and Originators: The Issuer has been established to acquire a portfolio of

residential mortgage loans (individually the “Loans”, collectively

and, together with the Collateral Security (as defined in Condition

2 (Status, Security and Administration)) relating thereto, the

“Mortgage Pool”):

(i) originated by Matlock London Limited (formerly

Matlock Bank Limited) (“Matlock”) trading as London

Mortgage Company (by itself or in association with a

Remote Processor (as defined under “Title to the

Mortgage Pool” below)) and acquired by Southern

Pacific Mortgage Limited (“SPML”);

(ii) originated by Langersal No.2 Limited (formerly London

Personal Loans Limited) (“Langersal”) and acquired by

SPML;

(iii) originated by SPML by itself or trading as the London

Mortgage Company (“LMC”) or in association with a

Branded Lender or a Remote Processor (each as defined

under “Title to the Mortgage Pool” below);

(iv) originated by one of the Correspondent Lenders (as

defined under “Title to the Mortgage Pool” below) and

acquired by SPML;

(v) originated by Southern Pacific Personal Loans Limited

(“SPPL”) by itself or trading as London Personal Loans

and acquired by SPML;

(vi) originated by Preferred Mortgages Limited (“PML”) by

itself or in association with a Branded Lender or a

Remote Processor; and

(vii) originated by Alliance & Leicester plc (“A&L”) and

acquired by SPML.

In this Prospectus:

(i) each of SPML and PML, in their respective capacities as

sellers of the Loans to the Issuer are referred to as a

“Seller” and together the “Sellers”; and

(ii) each of SPML, SPPL, PML, each Correspondent Lender,

A&L, Matlock and Langersal (in their respective

capacities as an originator of the Loans), are referred to

as an “Originator” and together the “Originators”.

The acquisition of the Mortgage Pool by the Issuer will be

financed by the issue of the Notes.

Edited March 28, 2010 by actionnotwords

[actionnotwords]

Hello Eagle

 

The FSA started to regulate mortgages on 31 October 2004. However, this regulation was limited to first charge loans.

 

If you have/had a second charge loan for more than £25k, provided before the removal of the £25k limit by the CCA 2006, you had an unregulated agreement.

 

Suetonius

Would regulation work retrospectively or is there a grey area as you indicate above.I had a similar experience some years ago when a lease agreement over what was then the cca limit of £15000 was found to my distress to be unregulated.

[brassed-off-2]

Eurosail-UK 2007-3BL: Notice to Noteholders | Company Announcements | Investegate

 

Interesting read, might be useful, or may not!! but you know me...like to google and post it up anyway!!

[actionnotwords]

The roles of the various lenders as specified in the prospectus.

 

Preferred Mortgages Limited

PML is a limited company incorporated in England and Wales under the Companies Acts 1985 and 1989 on 14 December 1995 (registration number 3137809). PML is engaged in the business of originating, purchasing and selling residential mortgage loans made to borrowers whose borrowing needs may not be met by traditional financial institutions in the UK residential market. PML is a subsidiary of an affiliate of Lehman Brothers International (Europe), the Lead Manager. However, such affiliate may consider offers in respect of its interest

in PML from time to time and may not continue to hold such interest for the duration of the life of the Notes.

The registered office of PML is at 6 Broadgate, London EC2M 2QS.

 

Southern Pacific Mortgage Limited

SPML is a limited company incorporated in England and Wales under the Companies Acts 1985 and 1989 on 15 October 1996 (registration number 3266119). SPML is the holding company of nine subsidiary companies incorporated in England and Wales under the Companies Acts 1985 and 1989 with limited liability and one subsidiary incorporated in Jersey (each, a “Subsidiary” and together with SPML and any other subsidiaries from time to time, the “UK Group”). The UK Group’s primary business is the origination of standard and nonstandard residential mortgages in the UK. SPML is a subsidiary of an affiliate of Lehman Brothers International(Europe), the Lead Manager. However, such affiliate may consider offers in respect of its interest from time to time and may not continue to hold its interest for the duration of the life of the Notes.

SPML’s registered office and principal place of business is at 1st Floor, 6 Broadgate, London EC2M 2QS.

 

Southern Pacific Personal Loans Limited

SPPL, an affiliate of SPML, is a limited company incorporated in England and Wales under the Companies Acts 1985 and 1989 on 25 October 2000 (registration number 4096093). SPPL’s entire issued share capital is owned by Resetfan Limited (registration number 3752197) whose registered office is at 1st Floor, 6 Broadgate, London EC2M 2QS. SPPL’s primary business is the origination of loans secured by second ranking residential mortgages or (in Scotland) by second ranking standard securities in the UK. SPPL also originates, where all prior mortgages or standard securities over a property are held by a single lender, some loans secured by mortgages or standard securities ranking immediately after the single lender.

SPPL’s registered office and principal place of business is at 1st Floor, 6 Broadgate, London EC2M 2QS.

SPPL will have sold the Loans originated by it and which are to be included in the Initial Mortgage Pool to SPML not later than the Closing Date.

Matlock London Limited (formerly Matlock Bank Limited)

Matlock London Limited is a limited company incorporated in England and Wales under the Companies Act 1985 and 1989 on 25 April 1958 (registered number 00603511). The registered office of Matlock London Limited is at Fourth Floor, Eagle House, 108-110 Jermyn Street, London SW1Y 6EE. Until 2 May 2006 it traded as the London Mortgage Company. On 14 May 2007, it changed its name from Matlock Bank Limited to Matlock London Limited.

 

Langersal No. 2 Limited

Langersal No. 2 Limited is a limited company incorporated in England and Wales under the Companies Act

1985 and 1989 on 1 November 1973 (registered number 01143030). The registered office of Langersal No. 2 Limited is at Fourth Floor, Eagle House, 108-110 Jermyn Street, London SW1Y 6EE. It was formerly called London Personal Loans Limited until it changed its name on 2 May 2006.

Edited March 28, 2010 by actionnotwords

[brassed-off-2]

The practice advised Lehman Brothers in

connection with the structuring and execution

of its first Eurosail transaction, a £746

billion multi-class bond issue backed by a

pool of non-conforming mortgages originated

by Southern Pacific Mortgage, a subsidiary of

Lehman Brothers. The bonds were issued by

Eurosail 2006-1, an Irish-incorporated special-

purpose vehicle, under a structure allowing

the client to issue future Eurosail transactions

with minimum changes to their documentation.

The bonds were listed on the Irish

Stock Exchange and rated by Moody’s, Fitch

and Standard & Poor’s.

 

Taken quote from here, page 965 weil gotshal manges

http://www.iflr1000.com/pdfs/Directories/2/United%20Kingdom%20England%20&%20Wales%202008.pdf

[actionnotwords]

I believe the fundamental and most critical current issue is the legal standing of Capstone through which all things flow and would be most grateful if this issue could be fully determined which if sucessful will then offer defendants some degree of protection.

I am reminded by previous posts of a leasing agreement I dealt with several years ago and I believe the same principle applies here.

1)The manufacturer(in this case the lender) sells the vehicle to a finance company (in this case the spv) the various warranties are included.

2)The finance company then leases the vehicle to the consumer for regular repayments.(and will sell for a nominal price once the lease period has finished)

3)The manufacturers role is over(unless the vehicle is faulty) the vehicle has been sold and there is no recourse back to them.

4)The finance company(spv) either collect payments directly or use an outside agency(capstone) to do the same.

5)If the consumer defaults on payments the finance company(spv) or its agents(capstone) take proceedings to recover the vehicle and charge the consumer for the remaining balance,the vehicle is then usually sold at a public auction.

 

6)You will note from this analogy that the manfacturers role ceases the moment the vehicle is sold.

7)The agents(capstone) for the finance company(the spv) have no relationship whatsoever with the manufacturer such a relationship is not necessary.

 

I would submit that this is exactly the case in our situation and is applicable to securitisation in the same way,the difference being that the "leasing contract" in our case is signed with the MANUFACTURER(LENDER) who still retains ownership of the vehicle by virtue of being registered as the legal titleholder at the land registry; and not the finance company(spv).

 

The conclusion being that the agent( Capstone) can and do only act for the finance company( spv) and as such have no capacity to act for the manufacturer(lender)

I URGE YOU TO CHECK THE PROSPECTUS BECAUSE THIS IS EXACTLY THE SAME RELATIONSHIP.CAPSTONE BRING AND ARE ONLY AUTHORISED TO BRING LITIGATION FOR DEFAULT ON BEHALF OF THE SPV AND NOT THE LENDER.

SUCH LITIGATION IS ILLEGAL AS THE SPV IS NOT THE LEGAL TITLEHOLDER.(OWNER)

Capstone have never been employed by or authorised by the lender and every case they have premised as acting for the lender could be challenged.

SO WRITE THE LETTER! then when you have sent it post

SHUT 'EM DOWN.

Edited March 28, 2010 by actionnotwords

[iconoclash]

Hi - anbl: it seems that SPPL made this move just prior to the regulations coming in late 2004 - it was they who suggested it on the telephone and these two companies were the only ones involved. The new mortg. was set up end Aug. 2004 at about £182k and redeemed from Birmingham Midshires which in turn was previously with GMAC and at £120k- having trawled through my files (such as they are) I see a very depressing path: SPML sold the mortgage to to Mortgage Agency Services No. Two by November 2005 - it was then redeemed the following year by a remortg. with Rooftops who then sold it to Future Mortgages, it was then redeemed in 2007 by GMAC (the broker stating that this was the only company to use) who then sold it to Oakwood - by then it had risen to 240K !! with all the charges and erc's - all of these mortgages were arranged by brokers apart from the SPPL/SPML deal - what's that quote about webs to weave? arrrrgh:x

NB I recall just one of these companies getting £11k+ in one fee alone

Edited March 28, 2010 by iconoclash
more text

[brassed-off-2]

Anyone else just had a problem with the cag server crasing and loosing posts??

[actionnotwords]

CAMPARI2

It is indeed a very twisted path and when called to book the main culprits usually the brokers disappear into the ether.

There is of course the misselling angle (the broker stating that this was the only company to use)but this would involve you bringing a claim unless you could involve a regulator such as the fos there are precedents and links for this if you feel you wish to pursue this course and it would be a no lose situation for you.

The brokers in many cases were induced by certain lenders by way of cash to recommend a particular product unknown to their actual clients (you)this is where the complaint lies.

[iconoclash]

HI anw: indeed. I will try to do what i can and want to get my PPI from GE Money also - they keep telling me to **** off so that will have to go to court. I'm hoping to get my mortgage statement etc from Capstone so I can see the calcs - am I right to say there is no law against them selling their own mortg. product to us via sppl at that time?