``... lenders rely on weak State regulatory oversight and legal loopholes to obfuscate revenue kickback schemes. Bank of America, Prospect Mortgage and Wells Fargo appear to be the most egregious at this form of pay-to-play. Common regional examples of tie-in schemes are: First Freedom Financial (Bank of America), a joint venture with Prudential Realty and Personal Mortgage Group/PMG (Wells Fargo), a joint venture with Remax Real Estate. It’s estimated that Bank of America and Wells Fargo by themselves utilize several hundred joint ventures across the U.S... These mortgage bankers clearly understand that kickbacks are against Federal laws yet they continue to cook up elaborate go-arounds to Federal and State statutes.''

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