AUDIT REPORT
A-PAN-AMERICAN MORTGAGE GROUP
NON-SUPERVISED LOAN CORRESPONDENT
CHICAGO, ILLINOIS
2004-CH-1007
AUGUST 9, 2004
OFFICE OF AUDIT, REGION V
CHICAGO, ILLINOIS
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Issue Date
August 9, 2004
Audit Case Number
2004-CH-1007
TO: John C. Weicher, Assistant Secretary for Housing, Federal Housing Commissioner and
Chairman of Mortgagee Review Board, H
Margarita Maisonet, Director of Departmental Enforcement Center, CV
FROM: Heath Wolfe, Regional Inspector General for Audit, 5AGA
SUBJECT: A-Pan-American Mortgage Group
Non-Supervised Loan Correspondent
Chicago, Illinois
We completed an audit of A-Pan-American Mortgage Group, a non-supervised loan correspondent
approved to originate FHA Single-Family mortgage loans. We selected A-Pan-American for audit
because it had a high loan default and claim rate. Our audit objectives were to determine whether: (1)
A-Pan-American’s Quality Control Plan, as implemented, met HUD’s requirements; and (2) A-Pan-
American complied with HUD’s regulations, procedures, and instructions in the origination of FHA
loans. The audit resulted in two findings.
In accordance with HUD Handbook 2000.06 REV-3, within 60 days please provide us, for each
recommendation without management decisions, a status report on: (1) the corrective action taken; (2)
the proposed corrective action and the date to be completed; or (3) why action is considered
unnecessary. Additional status reports are required at 90 days and 120 days after report issuance for
any recommendation without a management decision. Also, please furnish us copies of any
correspondence or directives issued because of the audit.
Should you or your staff have any questions, please contact Rose Capalungan, Assistant Regional
Inspector General for Audit, at (312) 353-6236 extension 2679 or me at (312) 353-7832.
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Management Memorandum
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Executive Summary
We completed an audit of A-Pan-American Mortgage Group, a non-supervised loan correspondent,
approved to originate FHA mortgage loans under the Single Family Direct Endorsement Program. The
audit was part of the activities set forth in our Fiscal Year 2003 Annual Audit Plan. We selected A-
Pan-American for audit because of its high loan default and claim rate. Our audit objectives were to
determine whether: (1) A-Pan-American’s Quality Control Plan, as implemented, met HUD’s
requirements, and (2) A-Pan-American complied with HUD’s regulations, procedures, and instructions
in the origination of FHA loans.
We concluded that A-Pan-American did not comply with HUD’s regulations, procedures, and
instructions in the origination of FHA-insured loans. It allowed unapproved branches and/or non-
employees to originate loans using A-Pan-American’s FHA lender identification number. Also, A-Pan-
American did not have an adequate Quality Control Plan or any evidence that it implemented the Plan.
Contrary to HUD’s requirements, A-Pan-American engaged in
A-Pan-American Allowed prohibited loan originations when it allowed unapproved
Prohibited Loan Originations branches and/or non-employees to originate 120 of 125 loans
using its FHA lender identification number. This occurred
because the President of A-Pan-American disregarded HUD’s
loan origination requirements in order to generate income from
the prohibited use of A-Pan-American’s FHA lender
identification number.
A-Pan-American Mortgage Group did not follow HUD’s
A-Pan-American Did Not Quality Control requirements. Although A-Pan-American had
Follow HUD’s Quality a Quality Control Plan, it was deficient because it did not
Control Requirements contain all the elements as required by HUD. In addition, A-
Pan-American provided no evidence it implemented its Quality
Control Plan.
We recommend that HUD’s Assistant Secretary for Housing-
Recommendations Federal Housing Commissioner and Chairman of the
Mortgagee Review Board: requires A-Pan-American to
indemnify/reimburse HUD for the appropriate amounts cited in
this report; and withdraws A-Pan-American’s approval to
participate in HUD’s Direct Endorsement Program. We also
recommend that HUD’s Director of Departmental Enforcement
Center: takes appropriate administrative action against A-Pan-
American; and seeks Civil Monetary Penalties against A-Pan-
American for the deficiencies cited in this report.
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Executive Summary
We provided our draft audit report to A-Pan-American’s
President and HUD’s staff during the audit. We held an exit
conference with A-Pan-American’s President on July 28, 2004.
We requested written comments from A-Pan-American by July
31, 2004. As of August 8, 2004, A-Pan-American did not
provided written comments to our draft audit report.
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Table Of Contents
Management Memorandum i
Executive Summary iii
Introduction 1
Findings
1. A-Pan-American Engaged In Prohibited Loan Originations 3
2. A-Pan-American Did Not Follow HUD’s Quality Control
Requirements 9
Management Controls 13
Follow Up On Prior Audits 15
Appendices
A. Schedule Of Questioned Costs And Recommendations For
Funds To Be Put To Better Use 17
B. Schedule Of Discrepancies – Finding 1 19
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Introduction
Section 203(b)(1) of the National Housing Act, as amended, authorizes HUD to provide mortgage
insurance for single-family homes. HUD must formally approve a lender that originates, purchases,
holds, or sells FHA-insured loans. These lenders must follow the statutory and regulatory requirements
of the National Housing Act and HUD’s regulations and guidelines. Lenders that do not follow these
requirements are subject to administrative sanctions.
In April 1998, HUD approved A-Pan-American Mortgage Group as a non-supervised loan
correspondent to originate FHA-insured loans. As a condition of its HUD’s approval, A-Pan-
American is required to develop a Quality Control Plan for the origination of loans. The Quality Control
Plan must be a prescribed function of A-Pan-American’s operations and assure that it maintains
compliance with HUD’s requirements and its own policies and procedures.
As a loan correspondent, A-Pan-American must send the FHA loans it originates to a HUD-approved
Direct Endorsement sponsor(s) for underwriting approval prior to loan closing and securing an insurance
endorsement from HUD. The loan origination process includes taking an initial loan application,
initiating the appraisal assignment, and obtaining the credit report, verifications of deposit and
employment. Based on the information gathered by the loan correspondent, the sponsor mortgagee
underwrites the loan and decides whether the borrower represents an acceptable credit risk for HUD.
Since the sponsoring lender bases its underwriting approval, in large part, on information gathered by a
loan correspondent, it is critical that the loan correspondent exercises due care and follows HUD’s
requirements.
In June 1997, A-Pan-American incorporated under the laws of the State of Illinois. Its Office is located
at 2815 North Kimball Avenue, Chicago, Illinois. A-Pan-American originated 125 FHA-insured
Single-Family loans totaling more than $18 million from October 2000 through September 2003. The
President of A-Pan-American is Jose R. Garcia-Camilo. A-Pan-American had business relationships
with three entities: RSPL Marketing, Inc. (4234 North Cicero Avenue, Chicago, Illinois), Outsource
Resource (16353 Rowley Lane, Lockport, Illinois), and New Concept Finance (5057 Harlem Avenue,
Chicago, Illinois).
Our audit objectives were to determine whether: (1) A-Pan-
Audit Objectives American complied with HUD’s regulations, procedures, and
instructions in the origination of FHA-insured loans, and (2) A-
Pan-American’s Quality Control Plan, as implemented, met
HUD’s requirements.
We conducted the audit at HUD’s Chicago Regional Office and
Audit Scope And A-Pan-American’s Office. We performed our audit work from
Methodology November 2003 through March 2004.
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Introduction
To accomplish our audit objectives, we interviewed: HUD’s
staff; and A-Pan-American’s employees and a contractor. We
reviewed HUD’s loan origination, Quality Control Plan, and
Quality Control Review requirements. We also reviewed A-
Pan-American’s Quality Control Plan for adequacy and
consistency with HUD’s requirements.
We analyzed all 125 FHA-insured loans originated under A-
Pan-American’s FHA lender identification number from
October 1, 2000 to September 30, 2003. We tested the loan
files to determine whether they were originated in accordance
with HUD’s requirements.
We also analyzed 24 of the 125 FHA-insured loans to
determine whether A-Pan-American implemented its written
Quality Control Plan. Our selection criteria included defaulted
loans, loans terminated with claims, and loans with invalid social
security numbers. Of the 24 loans, 7 were defaulted loans, 3
were loans terminated with claims, and 17 were loans for
borrowers with invalid social security numbers.
The audit covered the period from October 2000 through
September 2003. The period was adjusted as necessary. We
conducted the audit in accordance with Generally Accepted
Government Auditing Standards.
We provided a copy of this report to A-Pan-American’s
President.
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Finding 1
A-Pan-American Engaged In Prohibited Loan
Originations
Contrary to HUD’s requirements, A-Pan-American engaged in prohibited loan originations when it
allowed unapproved branches and/or non-employees to originate 120 of 125 loans using its FHA
lender identification number. This occurred because the President of A-Pan-American disregarded
HUD’s loan origination requirements in order to generate income from the prohibited use of A-Pan-
American’s FHA lender identification number. A-Pan-American’s unacceptable loan origination
practices contributed to its high loan default and claim rate, putting at risk more than $6.8 million in
FHA-insured loans.
Paragraph 1-2 of HUD Handbook 4060.1 REV-1 states that
HUD’s Requirements lenders (including loan correspondents) must be approved by
HUD to originate, purchase, hold, or sell FHA-insured
mortgages. Each branch office to which mortgagees intend to
submit mortgages must be registered with HUD. Further,
paragraph 2-14 states that all employees of the mortgagee
except receptionists, whether full time or part time, must be
employed exclusively by the mortgagee at all times.
Mortgagee Letter 00-15 states HUD prohibits approved
mortgagees from engaging in the practice of taking on an
existing, separate mortgage company or broker as a branch,
and allowing that separate entity to originate insured mortgages
under the approved mortgagee’s HUD mortgagee number.
This prohibited loan origination is called a “net branch”.
We reviewed all 125 of the FHA-insured loans (100 percent)
FHA-Insured Loans originated under A-Pan-American’s mortgagee name and FHA
Reviewed lender identification number between October 2000 and
September 2003. The 125 loans had a total value of
$18,106,689. Of the 125 loans, unapproved branches and/or
non-employees originated 120 loans valued at $17,284,080.
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Finding 1
Paragraph 1-2 of HUD Handbook 4060.1 REV-1 requires
A-Pan-American Engaged lenders (including loan correspondents) to be FHA-approved
In Prohibited Loan to originate FHA-insured mortgages. Additionally, when loans
Originations With Non- are originated from a branch, the branch must be registered with
Employees And/Or Entities HUD. In all cases, however, Mortgagee Letter 95-36 requires
That Were Not FHA- staff performing customary loan officer functions, either at a
Approved branch or main office, to be an employee of the approved
mortgagee.
Contrary to paragraph 1-2 of HUD Handbook 4060.1 REV-1
and Mortgagee Letter 95-36, A-Pan-American allowed
unapproved entities and/or non-employees to submit 120 loans
totaling $17,284,080 using A-Pan-American’s FHA lender
identification number. This type of loan origination engagement
is prohibited under Mortgagee Letter 00-15 because A-Pan-
American took on existing and separate non-FHA approved
entities as branches to originate insured mortgages using A-Pan-
American’s FHA lender identification number.
Verification with HUD’s Office of Lender Approval and
Recertification disclosed that the three entities and their
respective offices for RSPL Marketing Inc. (4234 North
Cicero Avenue Chicago, Illinois), Outsource Resource (16353
Rowley Lane Lockport, Illinois), and New Concept Finance
(5057 Harlem Avenue Chicago, Illinois) were not FHA-
approved or HUD-registered branch offices of A-Pan-
American Mortgage Group. All three entities were separate
mortgage companies or brokers from A-Pan-American.
In addition, we determined that 11 personnel who performed
customary loan officer functions on 120 of the 125 loans were
non-employees of A-Pan-American. The 11 personnel
performed customary loan officer functions of interviewing
clients; reviewing, processing and following-up on all of the
loan-related documents (credit report, appraisal, gift letters,
disclosures, certifications, etc.) necessary to complete the
clients’ loan origination packages; and interacting with the
sponsors to close the loan applications. The 11 personnel who
performed customary loan officer functions were not listed as
current or former employees on the employee list provided by
A-Pan-American to our Office.
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Finding 1
This condition occurred because the President of A-Pan-
HUD’s Requirements Were American disregarded HUD’s loan origination requirements.
Disregarded When A-Pan-American received its FHA license in 1998, we
concluded that the President intended to use its FHA lender
identification number to generate income by charging third
parties branch fees without having to participate in any of their
loan origination activities.
Our conclusion is based on our review of A-Pan-American’s
loan origination files, and receipt and payment transactions.
Our review disclosed that the President of A-Pan-American
earned at least $118,298 in passive income for 12 months by
charging branch fees to third parties for the use of A-Pan-
American’s HUD-approved mortgagee name and FHA lender
identification number. The President did this without: (1)
participating in the management and operations of the branch
offices; (2) providing any supervision or control over the branch
employees; or (3) performing Quality Control Reviews (see
Finding 2).
A-Pan-American President’s only participation in the business
activities of its unapproved branches and non- employees was
collecting the fees for the use of its FHA lender identification
number, as well as retaining the loan origination files after
closing each loan. A-Pan-American’s receipt and check
payment transactions revealed that a majority of the checks
written to A-Pan-American Mortgage Group were related to
branch fees. At least three checks payable to A-Pan-American
had a memo written on the face of the checks stating that these
branch fees were for the use of A-Pan-American’s license.
A-Pan-American’s unacceptable loan origination practices
A-Pan-American’s contributed to its high loan default and claim rate of 12 percent,
Practices Posed Significant putting at risk more than $6.8 million in FHA-insured loans.
Risks To The FHA
Insurance Fund If A-Pan-American’s FHA lender identification number to
originate loans was terminated, we estimate that approximately
$102,519 (average of 42 loans per year for the last three years
times A-Pan-American’s current claim rate of 3.17 percent
times HUD’s current average loss of $25,667 per home) in
FHA funds would be put to better use. This represents
potential savings to the FHA Insurance Fund in terms of
reduced risk.
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Finding 1
Although we found issues on 120 of the 125 FHA-insured
loans originated by prohibited branches and/or non-employees
using A-Pan-American’s mortgagee name and FHA lender
identification number, we are only requesting
reimbursement/indemnification on 54 of the 120 loans. The
remaining 66 loans are no longer considered a risk to the FHA
Insurance Fund since these loans were paid in full by the
borrowers. As of June 29, 2004, the insurance status for the
54 loans and their corresponding reimbursement/indemnification
amounts are shown in the following table. See Appendix B of
this report for more details.
Insurance Status Count Amount
Active 49 $6,541,291
Claim, Resold with Loss 4 145,056
Claim, Not Resold 1 128,296
Totals 54 $6,814,643
Recommendations We recommend that HUD’s Assistant Secretary for Housing-
Federal Housing Commissioner and Chairman of the
Mortgagee Review Board:
1A. Requires A-Pan-American to indemnify HUD
$6,541,291 against future losses on the 49 active loans
originated in violation of HUD’s requirements.
1B. Reimburses HUD $145,056 for the actual losses
incurred on the four terminated loans with a claim
originated in violation of HUD’s requirements.
1C. Reimburses HUD the appropriate amount of $128,296
for the future loss on one terminated loan with a claim
originated in violation of HUD’s requirements once the
property is resold.
1D. Withdraws A-Pan-American’s approval to participate
in HUD’s Single Family Mortgage Insurance Program
based on the deficiencies cited in this report. HUD’s
withdrawal should help ensure that $102,519 in HUD
fund is used appropriately.
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Finding 1
We also recommend that HUD’s Director of Departmental
Enforcement Center:
1E. Takes appropriate administrative action against the
owner of A-Pan-American Mortgage Group.
1F. Seeks Civil Monetary Penalties against A-Pan-
American for the deficiencies cited in this report.
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Finding 1
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Finding 2
A-Pan-American Did Not Follow HUD’s Quality
Control Requirements
A-Pan-American Mortgage Group did not follow HUD’s Quality Control requirements. Although A-
Pan-American had a Quality Control Plan, it was deficient because it did not contain all the elements as
required by HUD. In addition, A-Pan-American provided no evidence it implemented its Quality
Control Plan. The deficiencies existed because of A-Pan-American’s disregard for HUD’s Quality
Control requirements and its inability, as stated by its President, to access HUD’s Neighborhood Watch
system. As a result, HUD lacked assurance of the accuracy, validity, and completeness of A-Pan-
American’s loan origination operations.
HUD Handbook 4060.1 REV-1 includes the requirements for
HUD’s Requirements a mortgagee’s Quality Control Plan for the origination of FHA-
insured mortgages. Chapter 6 of the Handbook provides the
general requirements along with lender specific requirements for
Quality Control Plans. The Handbook requires mortgagees to:
§ Establish a Quality Control Plan that is sufficient in
scope to enable the lender to evaluate the accuracy,
validity, and completeness of its loan origination
operations;
§ Enable the lender to initiate immediate corrective
actions when discrepancies are found;
§ Assure records of Quality Control findings and actions
taken were kept;
§ Analyze loans that go into default within 6 months after
closing;
§ Indicate which of the two methods (for example 10
percent of all loans closed on a monthly basis or 95
percent confidence level with 2 percent precision) will
be used when sampling loans to be reviewed;
§ Retain the results of Quality Control Reviews for a
period of 1 year, whether performed by the mortgagee
or an outside firm; and
§ Perform Quality Control Reviews within 90 days of
closing of the loan.
A-Pan-American had a Quality Control Plan, but it was
Quality Control Plan Was deficient. Although the Plan identified the requirements of HUD
Deficient
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Finding 2
Handbook 4060.1 REV-1, it did not contain all of the elements
required. The Plan lacked procedures to ensure the accuracy,
validity, and completeness of A-Pan-American’s loan
origination operations. For instance, the Quality Control Plan
did not have:
§ Review procedures for ensuring all loans that defaulted
within the first 6 months were analyzed;
§ Review procedures for ensuring loans that closed within
90 days were reviewed; and
§ Selection sampling plan that identifies the sampling
method to be used and procedures to be followed
when selecting the samples.
The President of A-Pan-American copied HUD’s Quality
Control Plan checklist directly into the company’s business
letterhead, which was later, submitted to HUD as A-Pan-
American’s Quality Control Plan.
The President of A-Pan-American claimed that A-Pan-
No Evidence Of Plan American performed Quality Control Reviews. However,
Implementation when asked to provide evidence, he was unable to provide a
written report of Quality Control Reviews which would provide:
(1) information on how loans were selected for review; (2) a
listing of actual loans analyzed or reviewed; or (3)
documentation on the procedures or analyses actually
performed.
Moreover, our review disclosed that A-Pan-American did not
conduct Quality Control Reviews for the four early payment
default loans as shown in the following table.
Total
FHA Date Number Included
Loan Date First Last Of In HUD’s
Number Mortgage Payment Payment Payments Review
137- Amount Due Made Made
0843838 $352,265 05/01/01 10/01/01 6
1174619 $109,589 09/01/01 02/01/02 6 X
1457432 $170,012 01/01/02 04/01/02 4 X
1524050 $131,087 12/31/01 02/01/02 5 X
Totals $762,953 4 4 3
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Finding 2
Three of four early default loans in the table above were
included in HUD’s July 2003 Quality Assurance Review.
The Quality Control deficiencies occurred because A-Pan-
Causes Of Deficiencies American disregarded HUD’s Quality Control requirements.
A-Pan-American’s President said A-Pan-American did not
have access to HUD’s Neighborhood Watch system and
consequently, did not know the loans were in default.
In 1998, the President of A-Pan-American said he drafted a
Quality Control Plan based on a sponsor’s expert advice. This
was supplemented by a kit containing HUD’s Quality Control
Plan checklist that a sponsor (Aegis) provided. Later, we
found that A-Pan-American submitted a Quality Control Plan to
HUD containing information copied from HUD’s Quality
Control Plan checklist.
The President said he was unaware of HUD’s Neighborhood
Watch system and did not learn about the early payment
defaults until HUD’s Quality Assurance Division staff informed
him.
We do not believe the above reasons relieved A-Pan-American
of its responsibility to maintain a Quality Control Plan that meets
HUD’s requirements, as well as ensure that Quality Control
Reviews were conducted according to the Plan. In the absence
of maintaining and implementing an effective Quality Control
Plan, HUD lacked assurance of the accuracy, validity and
completeness of A-Pan-American’s loan origination operations.
Recommendations We recommend that HUD’s Assistant Secretary for Housing-
Federal Housing Commissioner and Chairman of the
Mortgagee Review Board:
2A. Requires A-Pan-American to fully establish and
implement an adequate Quality Control Plan and related
reviews, if HUD allows A-Pan-American to continue to
originate FHA-insured loans.
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Finding 2
2B. Reviews A-Pan-American’s implementation of
Recommendation 2A and ensure its Quality Control
process conforms to HUD’s requirements.
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Management Controls
Management Controls include the plan of organization, methods, and procedures adopted by
management to ensure that its goals are being met. Management controls include the processes for
planning, organizing, directing, and controlling program operations. They include systems for measuring,
reporting, and monitoring program performance.
We determined that the following management controls were
Relevant Management relevant to our audit objectives:
Controls
§ Program Operations – Policies and procedures that
management has implemented to reasonably ensure that the
loan origination process is in compliance with HUD/FHA
requirements, and the objectives of the programs are met.
§ Validity and Reliability of Data – Policies and procedures
that management has implemented to reasonably ensure that
valid and reliable data are obtained, maintained, and fairly
disclosed in reports.
§ Compliance with Laws and Regulations – Policies and
procedures that management has implemented to
reasonably ensure that resource use is consistent with laws
and regulations.
§ Safeguarding of Resources – Policies and procedures that
management has implemented to reasonably ensure that
resources are safeguarded against waste, loss and misuse.
We assessed all the relevant controls identified above during
our audit of A-Pan-American’s Quality Control and loan
origination processes.
It is a significant weakness if management controls do not give
reasonable assurance that resource use is consistent with laws,
regulations, and policies; that resources are safeguarded against
waste, loss and misuse; and that reliable data are obtained,
maintained, and fairly disclosed in reports.
Based on our review, we believe the items on the following
Significant Weaknesses page are significant weaknesses:
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Management Controls
§ Program Operations
A-Pan-American did not operate its loan origination program in
accordance with HUD’s requirements. A-Pan-American
allowed unapproved branches and non-employees to originate
FHA-insured loans contrary to HUD’s requirements. In
addition, A-Pan-American did not establish an adequate
Quality Control Plan and implement it accordingly (see Findings
1 and 2).
§ Validity and Reliability of Data
A-Pan-American did not perform Quality Control Reviews on
its loans for ensuring accuracy, validity and completeness of
loan origination operations (see Finding 2).
• Safeguarding Resources
A-Pan-American engaged in prohibited loan originations when
it allowed unapproved branches and/or non-employees to
originate loans using its FHA lender identification number. A-
Pan-American’s unacceptable loan origination practices
contributed to its high loan default and claim rate, putting at risk
more than $6.8 million in FHA-insured loans (see Finding 1).
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Follow Up On Prior Audits
This is the first audit of A-Pan-American Mortgage Group by HUD’s Office of Inspector General.
In July 2003, HUD’s Quality Assurance Division conducted a Title II origination review of A-Pan-
American. The review resulted in eight findings that included deficient Quality Control procedures, non-
compliance with HUD’s reporting requirements, violation of HUD’s loan origination requirements by
allowing unregistered branch office or non-employees to originate loans, and insufficient loan origination
documentation. As of June 29, 2004, all findings were not yet resolved.
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Appendix A
Schedule Of Questioned Costs And
Recommendations For Funds To Be Put To
Better Use
Recommendation Type of Questioned Costs Funds To Be Put
Number Ineligible Costs 1/ Unsupported Costs 2/ To Better Use 3/
1A $6,541,291
1B $145,056
1C $128,296
1E $102,519
Totals $145,056 $128,296 $6,643,810
1/ Ineligible costs are costs charged to a HUD-financed or insured program or activity that the
auditor believes are not allowable by law, contract, or Federal, State, or local policies or
regulations.
2/ Unsupported costs are costs charged to a HUD-financed or insured program or activity and
eligibility cannot be determined at the time of the audit. The costs are not supported by
adequate documentation or there is a need for a legal or administrative determination on the
eligibility of the cost. Unsupported costs require a future decision by HUD program
officials. This decision, in addition to obtaining supporting documentation, might involve a
legal interpretation or clarification of Departmental policies and procedures.
3/ Funds To Be Put To Better Use are quantifiable savings that are anticipated to occur if an
OIG recommendation is implemented, resulting in a reduced expenditure in subsequent
periods for the activity in question. This includes an implemented OIG recommendation that
causes a non-HUD entity not to expend Federal funds for a specific purpose. These funds
could be reprogrammed by the entity and not returned to HUD.
.
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Appendix B
Schedule Of Discrepancies – Finding 1
Loans Originated By Originated
FHA Insurance Unapproved Branch Offices By
Case Insured Closing Status As Non-
Number Amount Date of New Outsource Employees
06/29/04 RSPL Concept Resource
1 137-0646776@ $80,056 10/25/2000 T X
2 137-0677977@ 137,864 10/27/2000 T X
3 137-0713076 153,265 2/22/2001 T X
4 137-0766243@ 201,734 2/7/2001 A X
5 137-0788212 112,636 1/31/2001 T X
6 137-0814139 188,790 2/13/2001 T X
7 137-0822969 197,925 2/22/2001 T X
8 137-0824930 151,133 4/24/2001 A X
9 137-0827263 143,673 2/23/2001 T X
10 137-0838380 81,301 3/12/2001 T X
11 137-0838401 143,277 4/30/2001 A X
12 137-0840316 148,631 3/20/2001 T X
13 137-0859033 164,443 3/28/2001 A X
14 137-0864079 160,877 3/30/2001 A X
15 137-0874307 167,357 3/20/2001 T X
16 137-0879175 184,373 3/20/2001 T X
17 137-0890707 204,367 3/30/2001 T X
18 137-0900118 190,849 3/29/2001 T X
19 137-0915605 100,738 5/25/2001 T X
20 137-0944624 186,898 4/25/2001 A X
21 137-0950528 141,328 4/23/2001 A X
22 137-0970420 193,216 4/20/2001 T X
23 137-0972082 104,951 5/25/2001 T X
24 137-0972099 211,807 4/30/2001 T X
25 137-0982146* 164,018 4/30/2001 T X
26 137-0983447 113,527 4/24/2001 A X
27 137-0983634 110,127 4/24/2001 A X
28 137-0986335* 138,678 6/20/2001 T X
29 137-0991081 159,892 6/22/2001 A X
30 137-1035354* 168,000 5/2/2001 T X
31 137-1035485 128,550 5/16/2001 A X
32 137-1035654 55,723 5/23/2001 T X
33 137-1043236 102,604 5/1/2001 A X
34 137-1045295 135,198 5/22/2001 A X
35 137-1067906 205,669 5/29/2001 T X
36 137-1076482 84,397 6/4/2001 T X
37 137-1076517 101,560 5/24/2001 T X
38 137-1083497 98,962 5/25/2001 T X
39 137-1084197@ 192,971 5/14/2001 A X
40 137-1104505@ 177,493 6/1/2001 T
41 137-1104522 209,496 6/5/2001 T X
42 137-1104942 124,686 6/15/2001 T X
43 137-1110852 176,274 6/26/2001 T X
44 137-1111155 150,220 6/1/2001 T X
45 137-1137639 148,900 7/6/2001 T Legend:
X @ = The loans are purchases, all others are
refinances; * = The loans are covered by Section
234C of the National Housing Act, all others are
203B; A= active; T = terminated without claim; C =
terminated with claim.
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Appendix B
Loans Originated By Originated
FHA Insurance Unapproved Branch Offices By
Case Insured Closing Status As Non-
Number Amount Date of New Outsource Employees
06/29/04 RSPL Concept Resource
46 137-1147557 77,454 6/25/2001 A X
47 137-1147852 100,028 6/22/2001 A X
48 137-1151248 88,355 6/30/2001 T X
49 137-1151312 85,970 6/25/2001 A X
50 137-1182933* 75,370 7/18/2001 T X
51 137-1191856 156,685 7/24/2001 T X
52 137-1191879* 118,800 7/23/2001 T X
53 137-1236468 134,487 7/31/2001 A X
54 137-1250274 157,500 9/28/2001 T X
55 137-1250869 108,527 8/16/2001 A X
56 137-1254411 145,145 8/18/2001 T X
57 137-1275043 131,848 8/23/2001 T X
58 137-1275089* 113,700 9/4/2001 T X
59 137-1275230 74,907 8/22/2001 A X
60 137-1276531 137,385 8/29/2001 A X
61 137-1279731 141,135 8/31/2001 A X
62 137-1283220* 120,250 9/25/2001 A X
63 137-1283237 152,757 8/27/2001 A X
64 137-1286857 113,680 8/27/2001 T X
65 137-1286863 126,113 9/25/2001 A X
66 137-1303302@ 116,176 9/24/2001 A X
67 137-1305621 116,539 10/1/2001 A X
68 137-1328044 138,183 10/31/2001 T X
69 137-1333181 124,352 9/28/2001 A X
70 137-1356646 114,261 9/25/2001 A X
71 137-1408687 120,379 11/1/2001 T X
72 137-1410493 132,914 10/29/2001 T X
73 137-1410608 182,040 10/27/2001 T X
74 137-1417462 129,313 10/29/2001 T X
75 137-1417479 150,746 10/31/2001 T X
76 137-1444518 182,826 11/26/2001 T X
77 137-1445174 234,119 11/21/2001 T X
78 137-1446633* 149,600 11/21/2001 T X
79 137-1457432 170,012 11/26/2001 T X
80 137-1457449 176,813 11/30/2001 T X
81 137-1457455 123,221 11/27/2001 A X
82 137-1471218@ 129,174 11/30/2001 T X
83 137-1492927 134,741 2/19/2002 T X
84 137-1493793 127,890 12/19/2001 A X
85 137-1523712 165,713 12/24/2001 T X
86 137-1524067 122,464 1/16/2002 A X
87 137-1567401 190,718 2/15/2002 T X
88 137-1570026 119,770 3/22/2002 A X
89 137-1577893 138,050 1/17/2002 T X
90 137-1588765 139,409 2/21/2002 A Legend:
X @ = The loans are purchases, all others are
refinances; * = The loans are covered by Section
234C of the National Housing Act, all others are
203B; A= active; T = terminated without claim; C =
terminated with claim.
2004-CH-1007 Page 20
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Appendix B
Loans Originated By Unapproved
Insurance Branch Offices Originated
FHA Status As By
Case Insured Closing of Outsource Non-
Number Amount Date 06/29/04 RSPL New Concept Resource Employees
91 137-1600691 113,375 2/25/2002 T X
92 137-1615317 177,371 2/22/2002 T X
93 137-1646287 112,563 3/22/2002 A X
94 137-1669382 150,017 3/25/2002 A X
95 137-1722856@ 148,190 5/6/2002 T X
96 137-1722912@ 207,962 5/3/2002 T X
97 137-1846433 182,403 7/26/2002 T
98 137-1870376@ 118,146 7/25/2002 A
99 137-2111326 114,325 12/9/2002 A X
100 137-2159504 158,780 2/28/2003 T
101 137-2307924 185,787 4/4/2003 A
102 137-0843838 356,265 3/13/2001 C X
103 137-0874067 201,354 4/1/2001 A X
104 137-0971093 178,770 4/23/2001 T X
105 137-0983628 135,553 4/30/2001 T X
106 137-1010092@ 125,037 4/13/2001 A X
107 137-1035739 114,187 5/21/2001 A X
108 137-1035745 142,709 5/17/2001 C X
109 137-1035751 161,283 5/21/2001 C X
110 137-1053907 87,290 6/19/2001 T X
111 137-1075784 128,296 5/25/2001 C X
112 137-1086645@ 70,644 4/30/2001 A X
113 137-1163520 113,725 7/5/2001 A X
114 137-1171419 130,885 7/30/2001 A X
115 137-1174619 109,589 7/30/2001 A X
116 137-1202840 90,538 7/23/2001 T X
117 137-1250361 148,494 8/31/2001 A X
118 137-1250511 163,922 8/14/2001 A X
119 137-1404679 206,758 1/11/2002 T X
120 137-1409358 181,279 10/25/2001 T X
121 137-1410391 241,257 10/24/2001 T X
122 137-1488026 205,872 12/12/2001 A X
123 137-1524050 131,087 12/31/2001 C X
124 137-1558366 151,458 1/17/2002 A X
125 137-1669983 173,565 3/21/2002 A X
Totals $18,106,689.00 89 2 1 28
Legend: @ = The loans are purchases, all others are
refinances; * = The loans are covered by Section
234C of the National Housing Act, all others are
203B; A= active; T = terminated without claim; C =
terminated with claim.
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Appendix B
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INTENTIONALLY
2004-CH-1007 Page 22
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A-Pan-American Mortgage Group, Non-Supervised Loan Correspondent, Chicago, IL
Published by the Department of Housing and Urban Development, Office of Inspector General on 2004-08-09.
Below is a raw (and likely hideous) rendition of the original report. (PDF)