Three Choices and More
There are two versions of the Reverse Mortgages, which are known as Home Equity Conversion Mortgages (HECM). There is the traditional HECM refinance which includes the Line of Credit where applicable and the more recent HECM purchase product. All are designed to benefit folks age 62 and above. Within both the Purchase and the Refinance is an option for either a Fixed or an Adjustable rate. With the traditional HECM one may set up a line of credit which grows at a handsome and tax free rate and may do so with minimal closing costs.
The point is, there is a great deal of flexibility today to design a product best suited for an individual’s or couple’s needs and wants. In fact, if desirable, one can make monthly payments as on a home equity line of credit or mortgage. Keep in mind that monthly mortgage payments are not required.
Insured and Guaranteed by the USA
Both the traditional HECM refinance and the HECM purchase are insured by the Federal Housing Administration (FHA) and guaranteed by the US Department of Housing and Urban Development (HUD) as discussed by the Federal Deposit Insurance Corporation (FDIC) and further explained by the Consumer Financial Protection Bureau (CFPB).
The HECM can be used for FHA acceptable properties of 1-4 units, provided one unit is occupied by the owner. In addition, it can be used for an FHA approved condominium as well as an FHA acceptable manufactured home.
Recent Media Publications
“Will I run out of money before I die?” George Gagliardi gets that question all the time from clients. A certified financial planner in Lexington, Mass., Gagliardi rarely dishes out a simple answer. Instead, he explores creative solutions to preserve retirees’ funds. This adviser says not to buy long-term-care insurance — and to do this instead Morey Settner Market Watch June 13, 2017
“In any case, preserving an inheritance probably shouldn’t be your top priority. You should focus instead on preserving your quality of life and your financial flexibility.” Liz Weston, June 11. 2017 L.A. Times Why a reverse mortgage might be a good idea for some older homeowners
What’s stopping seniors from accessing the wealth stored in their home equity? The most important factor affecting low rates of home equity extraction among seniors is limited demand, which might arise for two reasons: • Seniors are typically financially conservative and want to avoid debt. This behavior could be related to their desire to leave a bequest or to save for emergency expenses or long-term care. Others might avoid mortgage debt because they’re worried about losing their home. • Continued improvements in health and medicine are allowing more seniors to work and earn well into old age, reducing the need to depend on home equity extraction. Published by Urban Wire on February 27, 2017
Homebuilders Are Betting on Boomers to Be Big Buyers is the title of an article published in the National Mortgage News on January 23, 2017. Of essence to the article is the high cost of purchasing a home. As stated, “… boomer buyers are finding that home cost is the biggest issue in making their move.” A solution to consider, for many in this situation, is the Purchase Reverse Mortgage.
China’s Real Estate ‘Godfather’ Says Reverse Mortgages Are The Answer “Under these circumstances, participating in the house-for-pension plan can be regarded as an important option for China’s elderly to improve their living conditions and live better in their later years,” New York Times December 26, 2016 | Of note, reverse mortgages or house pensions are utilized in, among others, the following countries: Australia, Canada, Germany, India, Japan, Korea, New Zealand, Norway, Spain, Sweden and the United Kingdom where they are known as Equity Releases.
‘Silver’ Divorce Puts Strain On Retirement Income “…an often overlooked and underutilized tool for dividing assets in silver divorces is the reverse mortgage. A reverse mortgage can be used to provide the liquidity needed to help divide the value of the home, paying out the spouse who wants the money while allowing the other spouse to remain in the home without making any mortgage payments. Monthly mortgage payments could be a huge strain on his or her retirement income each month.” Forbes October 24, 2016 Jamie Hopkins | Further reference: Using Housing Wealth to Facilitate Asset Division in “Silver Divorce” by Barry H. Sacks, Ph.D., J.D. and Stephen R. Sacks, Ph.D.
CONFLICT OVER INHERITANCES – “Mary’s going to do what’s good for Mary” … some children of clients may expect an inheritance in the form of the family home. But as reverse mortgages and home equity loans become more popular, …those real estate windfalls are likely to decline Excerpted from THE LONGEVITY PARADOX by Elizabeth MacBride on August 22, 2016 and republished in the Investment News on December 24, 2016.
5 Ways A Reverse Mortgage Can Help Your Retirement October 12, 2016 Forbes.com “The old notion that reverse mortgages should only be taken out as a last resort simply is no longer true today. In fact, I believe there are five ways reverse mortgages can improve your retirement income plan. …There is a healthy skepticism about reverse mortgages, and that’s not necessarily bad, because people should exercise caution when utilizing debt. But reverse mortgages can improve retirement spending outcomes in a sensible way.”
A Surprising Suggestion for Retirement Income October 10, 2016 TIME.com/Money “Used strategically, a reverse mortgage can greatly improve the sustainability of your retirement income,” says Pfau, a professor of retirement income at the American College of Financial Services. For instance, you might use a reverse mortgage to provide income for several years while you delay claiming Social Security–or you could tap a reverse-mortgage line of credit to minimize withdrawals from your portfolio in a stock-market downturn. You should consider signing up for a line of credit early in retirement even if you don’t think you will ever need it.
How will you manage longevity risk? There are some time-honored ways to deal with the risk of outliving your assets. Those include the use of annuities, a sound asset-drawdown plan, delaying Social Security to age 70 for the higher wage earner, and a reverse mortgage. October 5, 2016 USA TODAY For your retirement planning, count on living until age 95 by Robert Powell
The Street published an announcement titled The American College Of Financial Services Aligns With Funding Longevity Task Force on September 28, 2016. This is a significant combination of forces which will be of great help in bringing Reverse Mortgage Facts to the forefront of Financial Planners for the benefit of American Consumers.
“The American College of Financial Services, the nation’s largest nonprofit educational institution devoted to financial services, and the Funding Longevity Task Force announce a partnership designed to expand the body of knowledge on issues related to reverse mortgages and home equity in retirement planning.” To continue reading, click here.
Retire on the House: The Use of Reverse Mortgages to Enhance Retirement Security July 26, 2016 MIT Center on Finance and Policy “There is a near-consensus in the professional literature that many, perhaps, most American households working today will face a significant retirement funding gap, on present trends, behaviors, conditions, and policies. Some have even gone so far as to term this finding in the literature a retirement crisis. Although many solutions have been offered to reduce the estimated funding gap, that is, to improve the retirement security of working households and even current retirees, this paper focuses on one that uses a currently available financial tool – the reverse mortgage, also known as the HECM (home equity conversion mortgage).”
A Reverse Mortgage to Buy a Home? Here’s How | “Here’s how it works: Seniors 62 or older buying a primary residence make a down payment and pay closing costs. They then get a lump-sum loan that goes toward the home purchase. No monthly payments are required to pay down the debt. Instead, interest accrues on the loan, and the principal and interest are usually due when the last co-borrower or spouse on the loan moves out or dies.” Published by the Wall Street Journal on June 20. 2016.
“…protect your portfolio in retirement … But only if you open a reverse mortgage line of credit early in retirement for just this purpose.
Good financial planners have long hated reverse mortgages, which allow people 62 and over to tap their home equity without having to make payments on the debt. Advisors traditionally have seen these loans as a last resort for retirees who exhaust all their other assets.
Today’s reverse mortgages are cheaper and safer than in the past, however, thanks to improvements in the Federal Housing Administration’s Home Equity Conversion Mortgage program. Also, recent research indicates that reverse mortgage lines of credit offer an important safety valve in retirement. When the stock market plummets, retirees can tap credit lines instead of their portfolios, which allows their investments time to recover when the market rises. This “standby reverse mortgage strategy,” as some researchers call it, significantly improves the odds of a portfolio lasting through retirement.” Published in NerdWallet on June 20, 2016 in an article by Liz Weston titled 5 Good Reasons to Tap Your Home Equity.
“We also propose to strengthen programs that support and advise consumers on reverse mortgages, which can be a good option for some older Americans.” Securing Our Financial Future a report titled the Report of the Commission on Retirement Security and Personal Savings from the Bipartisan Policy Center, published June 9, 2016.
Click on the Bolded title to view a 2:23 minute video featuring Jane Bryant Quinn, author of How to Make Your Money Last: The Indispensable Retirement Guide titled Why a reverse mortgage may be right for you. In this brief video, Ms. Quinn discusses the changed rules of reverse mortgages which provide greater protection for consumers. CNNMoney, May 11, 2016.
“Steven Sass, program director at the Boston College Center for Retirement Research, says that reverse mortgages make sense not just for low-income people who want to stay in their homes but also for wealthier retirees who have considerable equity but want to goose their income streams.” Written by Dave Lindorff and, published on May 1, 2016 in FIANCIAL PLANNING.
“. . . opening the line of credit at the start of retirement and then delaying its use until the portfolio was depleted created the most downside protection for the retirement income plan. This strategy allowed the line of credit to grow longer, perhaps surpassing the home’s value before it was used, which provided a bigger base to continue retirement spending after the portfolio was depleted. Using home equity last did reduce upside potential, because when markets were strong the portfolio grew faster than the loan balance.” Journal of Financial Planning: Incorporating Home Equity into a Retirement Income Strategy by Wade D. Pfau, Ph.D., CFA., published by the Financial Planning Association, 2016.
Why Financial Advisors and Reverse Mortgages Don’t Get Along “As a practical matter, (financial) advisors who don’t have mortgage licenses can’t make direct commissions from a HECM or earn a finder’s fee for a HECM referral,” writes Kerry Pechter for the Journal. “Second, most brokerage advisors don’t practice ‘life-cycle’ investing, which considers an investors’ entire ‘household balance sheet,’ including home equity.” Published in Reverse Mortgage Daily on April 25, 2016.
“…you could set up a reverse mortgage as a standby line of credit, says John Salter, a certified financial planner and professor of personal financial planning at Texas Tech University in Lubbock. That way the money is available if you have big unexpected expenses, such as a health emergency. “It’s there if you need it, and if you don’t, you never need to tap it,” he says.
Also, Salter suggests that if the financial markets are down, you could take income from a reverse mortgage line of credit rather than from other investments. Once those investments recover, you can repay the loan. You could also put off taking Social Security longer by using a reverse mortgage to supplement income early in retirement. Delaying Social Security allows the benefit payment to grow, which would give you a higher lifetime guaranteed income stream that is adjusted for inflation.” Writes Donna Rosato in an article titled Reforms Come to Reverse Mortgages published by Consumer Reports on April 4, 2016.
Home Title: A commonly held false belief is that the lender receives the title to the home as part of a reverse mortgage. This is simply untrue. It is an enduring myth about HECM reverse mortgages. Professor Wade Pfau discusses this and other misconceptions of the reverse mortgage in the Forbes article, of February 23, 2016, titled, How Did Reverse Mortgages Get Such a Bad Reputation?
“Reverse mortgages have long suffered from a negative public perception. The problem is the result of several factors, including common misconceptions about a somewhat complicated financial product that have been hard to dispel. Most Americans simply don’t understand the ins and outs of the product, with many holding on to the false belief that the bank owns a borrower’s home. Even some financial professionals are uninformed about the details of the loan.” Writes Jessica Guerin in a excellent feature article titled, The Public’s Perception published by the Reverse Review in their February 2016 issue.
Evaluate how to use the house as a financial asset to produce retirement income: For many middle-class Americans, the home represents their single greatest financial asset. A good planner should be able to decide if a reverse mortgage is a good fit for your situation. A great planner should know about how the standby reverse-mortgage strategy can be used to extend the time you will have usable financial assets in retirement… The above excerpt is from a brief, yet comprehensive, discussion of what a great financial planner needs to know about retirement planning. This was written by Kenn Tacchino and published in Market Watch on January 26, 2016.
Beth Patterson, a fellow blogger and a remarkable reverse mortgage professional in MN offers many factual observations in her post of January 11, 2016 titled: What You Need To Know When A Reverse Mortgage is Due and Payable – Respond Quickly. She offers this excellent question: “How long do I or my children have to pay off the reverse mortgage?” On this, one of her observations is: Once a loan payoff is requested the funds from one’s line of credit and/or monthly payments will be frozen. If you, the borrower, are thinking funds will be needed for the move, fixing the home for sale, etc. make sure funds are requested prior to the move and payoff request. The heirs, because they are not borrowers, cannot request funds.
The following comprehensive study of utilizing a reverse mortgage to maximize retirement income in conjunction with conventional retirement income streams is primarily directed to professional Financial Planners. I have captured a few lines from their conclusion for those of us in the lay community. “We have considered retirement income in the classic mode of constant purchasing power (except where the safeguards are invoked) over periods of up to 30 years. The income sources we have considered consist of a securities portfolio plus withdrawals from home equity by means of a reverse mortgage credit line…We have also found that use of these active strategies is likely to result in a higher residual net worth after 30 years than the use of the conventional strategy.” Reversing the Conventional Wisdom: Using Home Equity to Supplement Retirement Income by Barry H. Sacks, J.D., Ph.D., and Stephen R. Sacks, Ph.D. Published in the Financial Planning Association in February 2012.
On using the reverse mortgage as an income vehicle: “The second benefit of opening the reverse mortgage early, especially when interest rates are low, is that the principal limit that can be borrowed will continue to grow throughout retirement. Reverse mortgages are non-recourse loans, and for sufficiently long retirements there is a reasonable possibility that the line of credit may grow to be greater than the value of the home. I wrote about this last year. In those cases, the mortgage insurance premiums paid to the government on the loan balance are used to make sure the lender does not experience a loss, but also the borrower and/or estate will not be on the hook for repaying more than 95% of the appraised value of the home when the loan becomes due.” For the rest of the article see, Advisors Need a Fresh Look at Reverse Mortgages by Wade D. Pfau, Published in the Advisors Viewpoint on December 1, 2015.
“…a lot has changed in the past several years, and the result is that reverse mortgages have an undeserved bad reputation.” States Wade D. Pfau in The Experts segment of the Wall Street Journal on November 30, 2015 in an article titled The New Case for Reverse Mortgages.
“…if you are looking for a big lever, a reverse mortgage line of credit will be the most powerful tool available for many people.” This statement was written by Scott Burns and published in the Dallas Morning News on October 23, 2015 in an article titled Do reverse mortgages help out?
The Financial Planning Association recently published an analysis of the HECM as a source for supplemental income for Baby Boomers. This is an excellent read for all even though it is directed to financial planners. Retirement Trends, Current Monetary Policy, and the Reverse Mortgage Market.
Citing John Salter, associate professor of personal financial planning at Texas Tech University, The Dallas Morning News states that opening a credit line while interest rates are low—even if the borrower does not need the money now—can result in a larger credit line now than when rates are higher. 6 strategies to stretch your retirement savings. Published September 23, 2015.
In the September 2015 issue of The Reverse Review, Jason Perez published an article titled: When the Last Surviving Borrower Dies. In part, he writes, “I regularly receive questions about what happens when the last surviving borrower dies, and when I think back to my responses just a few years ago, I realize they were once very simple. But in the wake of major product change these past two years—like so much within our product and industry—it has gotten complicated! I’ll do my best to simplify what has become a more layered, complex and ultimately rewarding process for borrower’s heirs and estates…”
On August 28, 2015, the Wall Street Journal published an article by Jason Zwieg titled: Buying The Dips Doesn’t Work For Everyone. An essence of this post highlights the value of setting up a HECM Line of Credit as a standby for troubling financial times. The point missed is for optimal results, one should set up the HECM LOC a the earliest opportunity. “…Another possibility, says Prof. Pfau, is to consider taking out a line of credit under the Home Equity Conversion Mortgage program guaranteed by the federal government, using it only during periods when the value of your stock portfolio is declining. This way, you reserve the right to borrow against your home at reasonably competitive rates. But you would draw on the money only at times when you would otherwise have to lock in losses on your stock portfolio.”
4 Advantages FHA Reverse Mortgages Have Over HELOCs by JEFF TAYLOR was published by Origination News on September 4, 2015. The information is primarily for financial planners. The content is good and mostly accurate; for clarity, the actual Mortgagee Letter discussed is 2015-02. A paragraph I particularly like is: “Although it’s often the subject of negative press, the HECM product is sound. Complaints emerge largely from “last resort” borrowers versus borrowers seeking a retirement supplement or a HELOC option. The education gap, and occasional “piling on” of negative media stories, has unfairly tarnished the HECM reputation. Consumer Financial Protection Bureau data shows HECM complaints are minimal compared with forward mortgage complaints.”
Robert Massi of Fox News published: Is a reverse mortgage right for you? on August 21, 2015. While the article has several good points for the traditional reverse mortgage, it simply does not address the purchase reverse mortgage. However, this cautionary sentence adds great value to the post: “Beware of the hard sell. Unscrupulous brokers may target older people and offer high-cost loans. If a salesman tries to convince you that a reverse mortgage can be used to free up money for investment in other financial products, like annuities or long-term care insurance, walk away.”
On August 7, 2015, the New York Times published an article titled 6 Strategies to Extend Savings Without Working Longer. In part, the discussion focuses on the reverse mortgage as a forward looking strategy for retirement income stability: “One approach is a standby reverse mortgage, where borrowers open a line of credit that can be tapped when necessary. Opening a credit line while interest rates are low, even if you don’t need the money now, can result in a larger credit line now than when rates are higher, said John Salter, an associate professor of personal financial planning at Texas Tech University. And the line of credit continues to grow over time.”
In the May 18, 2015 issue of Forbes, Jamie Hopkins published an article suggesting how to use the New Reverse Mortgage titled: New Reverse Mortgage Rules Open Door To A More Secure Retirement. His article examines three different strategic uses of reverse mortgages within a retirement income plan and illustrates how these strategies are for more than just the cash-poor, house-rich client.
In April, 2015, The Motley Fool reproduced a report from the FBI which they titled, Don’t Get Duped! How to Avoid Reverse Mortgage Scams According To the FBI. It is brief and to the point; it’s well worth the time for your review.
On January 9, 2015, Consumer Affairs reporter, Mark Huffman published: A reverse mortgage should always be in both spouses’ names. This article nicely summarizes the new rule whereby a spouse under the age of 62 may remain in the property when the older spouse pre-deceases the younger mate. Very briefly, you will wish to make sure both names are on the title to the property. Feel free to contact me for information you will wish to share with your legal advisor.
In a November 24, 2014, CBS News’ MoneyWatch writer Steve Vernon, discusses several options one should consider to supplement retirement income and savings, these include utilizing a reverse mortgage. Mr Vernon referenced the acclaimed Boston College eBook (below) in writing this article: Should you use your home equity for retirement income?
PLANADVISER (writes) that a reverse mortgage “could be right if you plan to stay in the house your entire life. It’s not great if you are going to move. Of course, you don’t know if you’re going to move, so there’s risk, but there’s risk in everything.”
“…many retirees could benefit from paying the closing costs necessary to have a reverse mortgage line of credit (which lenders can’t close down, unlike home equity lines of credit) on standby for times when their investments have fallen.” Love Them or Loathe Them, Reverse Mortgages Have a Place New York Times, September 26, 2014
A must read: USING YOUR HOUSE for INCOME IN RETIREMENT. This is a fabulous, brief eBook from Boston College written for folks like you and me. It is fun and easy to read, loaded with info graphs. Contact me for a no-cost to you copy.
Reverse mortgage can be a useful financial tool: “For consumers, the most important thing they can do is to become educated on how (a reverse mortgage) works… A reverse mortgage is not the solution for everybody, but clearly it’s an option for many people and the more information they know, the better they can understand how the product works and they can make an informed decision.” September 5, 2014 published in The Houston Chronicle.
The Boston Globe on June 3, 2014 published New reverse mortgage rule aims to keep surviving spouse in home which does a reasonably good job of explaining the new rules being implemented by FHA on August 4, 2014. In part, these new rules allow the surviving spouse who was not age 62 at the time the mortgage to remain in the home following the death of the older spouse who was on the mortgage. The surviving spouse simply needs to pay the taxes, insurance, HOA dues (if applicable) and maintain the property.
“If you are approached by a financial professional to do a reverse mortgage in order to fund a particular investment, keep in mind that all investments carry risk and costs—and the higher the promised return, the higher the risk. It’s best to steer clear of investments that are risky or underdiversifed—as well as those that make it expensive, if not impossible, for you to access your money if unexpected expenses arise.” from a position statement titled Reverse Mortgages: Avoiding a Reversal of Fortune published by the Financial Industry Regulatory Authority on May 1, 2014.
Reverse Mortgages: What Advisors Should Know: “If you think that reverse mortgages are only for cash-strapped retirees without any other financial options, think again. The features of reverse mortgage loans have been evolving over the years and a growing body of research suggests that these loans can help older adults manage a dependable stream on income during their retirement years.” April 21, 2014 published in bic by Paul Norr
“…elder law and reverse mortgage experts say they frequently encounter resistance from children less concerned about the terms of the loan than about losing their presumed inheritance.” April 10, 2014 New York Times by Lisa Prevost titled: Reverse Mortgage Realities.
NBC News reporter Shelley K. Schwartz published an article on March 24, 2014 titled: Reverse Mortgage: Sounds Too Good To Be True. How Does it Work? This article outlines how the loans work and the costs tied to them. The article is brief and refreshingly accurate.
The Wall Street Journal published an article on March 22, 2014 written by Tom Lauricella titled: A Kinder, Gentler Reverse Mortgage focusing on recent safeguards and borrower protections implemented by FHA.
For an in-depth, academic look at reverse mortgages as a financial planning tool for retirement, an article written by David W. Johnson, Ph.D and Zamira S. Simkins, Ph.D recently published in the Journal of Financial Planning titled Retirement Trends, Current Monetary Policy, and the Reverse Mortgage Market offers very clear insights into the suitability of the product and is particularly suited for professionals.
Kiplinger’s Retirement Report Published in March 2014 has an excellent article by Rachel L. Sheedy titled What Heirs Need To Know About Reverse Mortgages.
The New York Times published an article on February 14, 2014 titled Retiring On The House discussing the facts of this product. It is brief and to the point, I encourage all to read it.
For facts on the costs of a reverse mortgage, read Beth Paterson’s blog – Surprise! Reverse Mortgage Closing Costs Actually Compare to Conventional Mortgage Costs.
NASDAQ released an article on February 5, 2014 written by Joe Young titled Reverse Mortgages: The Pros and Cons. I will add one “Con” that Mr. Young did not mention and that is proceeds from a reverse mortgage should not be used to purchase an annuity or mutual funds without the advise of both a Reverse Mortgage HUD Certified Housing Counselor and an attorney specialized in Elder Law to make certain there are no abuse of trust issues.
The Government’s Redesigned Reverse Mortgage Program from the Boston College Retirement Center – January 2014 – Click Here for the Summary
Aldo Svaldi of The Denver Post published an article on September 29, 2013 titled FHA tightens the rules on reverse mortgages discussing changes about to be implemented by FHA. These changes are meant to preserve the HECM program by lowering the available cash and limiting the distribution in many cases. This has a relatively minimal impact on the Purchase Reverse Mortgage program.
“I cannot find a downside,” Fran Ciaccia, a retired high school cafeteria cook from Levittown, Pennsylvania, said in an interview. “We have told so many people about it.” This quote from the blog: Reverse Mortgages Get No Respect published July 25, 2013.
An excellent comment was posted to the Wall Street Journal defending homeowners’ rights to access their Housing Wealth (published 12/21/2012).
As reported June 20, 2012 on PBS’s Money File: “You’ll never owe more than the house is worth, no matter how high interest rates go or how many payments you’ve received. The mortgage is due in full plus interest and fees only when you move, die or sell the home. Any remaining equity belongs to you or your estate.”
As Tom Kelly wrote in Inman News on June 6, 2012: “ …While there were some huge mistakes with the early reverse mortgages that were compounded by a few bad operators, today’s product is a needed, helpful tool that provides thousands of seniors access to funds otherwise untouchable. How many conventional lenders will grant a loan to a 70-year-old with no income?
Reverse mortgage rates and fees have come down. Fixed-rate programs are now in place. There is no other product where greater care is given, more counseling is mandatory and more questions are answered before anything is done.”
On May 22, 2012, real estate expert John Adams joined Good Day on FOX News Atlanta, reported in part: “Several years ago, the concept of a reverse mortgage was introduced, but they were very expensive and hard to understand. Today, FHA has created a program that meets many senior needs at a reasonable price point.”
On May, 11 2012 CBS 42 of Birmingham, AL broadcast a Special Report titled: Is a reverse mortgage right for you? One consumer discovered this of her reverse mortgage,” . . . it’s been a win-win situation. After losing her husband of 51 years to lung cancer, she thought the dark clouds would ever go away. Thanks to a reverse mortgage, her financial worries are gone and her skies are sunny and clear once again. “I feel comfortable,” she said. “I know now that I don’t have to do something drastic.”
DISCLAIMER – This blog post does not represent that any of the information provided is approved by HUD or FHA or any US Government Agency.
Financially Speaking™ James Spray, RMLO, CNE, FICO Pro
CO LMO 100008715 | NMLS 257365 | Updated frequently
Notice: The information on this blog is opinion and information. While I have made every effort to link accurate and complete information, I cannot guarantee it is correct. Please seek legal assistance to make certain your legal interpretation and decisions are correct. This information is not legal advice and is for guidance only. You may use this information in whole and not in part providing you give full attribution to James Spray.