January 2008
Authors:
Steven M. Kaplan
+1.202.778.9204
steven.kaplan@klgates.com
Nanci L. Weissgold
+1.202.778.9314
nanci.weissgold@klgates.com
Lorna M. Neill
+1.202.778.9216
lorna.neill@klgates.com
K&L Gates comprises approximately
1,500 lawyers in 24 offi ces located in
North America, Europe and Asia, and represents capital markets participants, entrepreneurs, growth and middle market companies, leading FORTUNE 100 and
FTSE 100 global corporations and public sector entities. For more information, please visit www.klgates.com.
www.klgates.com
As millions of baby boomers reach retirement age, reverse mortgages and similar fi nancing products that enable seniors to tap into their home equity are gaining tremendous popularity.
State and federal legislators and regulators are taking note and proposing numerous measures to regulate reverse mortgages. This Client Alert discusses a number of important legislative developments on reverse mortgages in 2007 and previews reverse mortgage policymaking in 2008.
* * * * *
In the last weeks of 2007, the U.S. Congress took several signifi cant steps toward changing the rules governing the booming market for reverse mortgages. The U.S. Senate Special
Committee on Aging held a hearing to consider the potential benefi ts and perils to consumers of reverse mortgages.
1
Senators Claire McCaskill and Herb Kohl fi led the Reverse Mortgage
Proceeds Protection Act, legislation to address concerns about predatory lending practices in the rapidly growing reverse mortgage industry.
2
Finally, the U.S. Senate passed the FHA Modernization Act,
3
which proposes a number of changes to HUD’s reverse mortgage program, the Home Equity Conversion Mortgage
(“HECM”) program. The House of Representatives passed companion FHA reform legislation in September 2007, which proposes new rules for HECMs similar to those in the
Senate bill.
4
The House FHA reform bill differs from the Senate version in signifi cant ways not related to HECMs, however.
In addition to proposing many more publicized FHA reforms, the FHA Modernization Act would amend the HECM program in fi ve ways aimed at increasing the availability of HECMs and the funds available to HECM borrowers, and lowering the costs of HECMs.
1. Lift the Annual Cap on HECMs .
The Act would eliminate the 275,000 annual cap on the number of HECMs that FHA can insure each year.
5
2. Increase the Available Loan Amount.
The Act would implement a single national loan amount for HECMs equal to the government-sponsored conventional singlefamily loan cap, currently set at $417,000.
6
Currently HECM mortgage limits vary according to the FHA loan limit for a particular area.
3. Permit HECMs on Cooperative Units .
The Act would expand the availability of the HECM program to cooperative unit owners.
4. Lower Origination Fees.
The Act would require HUD to lower the cap on HECM origination fees from 2 percent to 1.5 percent of the maximum amount allowable for the loan.
7
At the same time, the legislation would give HUD the option to raise this cap in the future based on “the costs to the mortgagor” or “the impact of such fees on the reverse mortgage market.”
8
In addition, the Act would require HUD to issue regulations that set a new minimum allowable amount for origination fees
9
, provide that the origination fee may be fully fi nanced with the mortgage, and include any fees paid to correspondent mortgagees.
10
Mortgage Banking & Consumer Credit Alert
5. Mandate HUD Review of HECM Costs.
The Act would require HUD to submit a report to
Congress 12 months after the fi nal enactment of the
FHA Modernization Act on the effects of limiting the amounts of costs or fees under the HECM program.
11
The HUD report must include information regarding the current costs to borrowers of participating in the HECM program, the fi nancial soundness of the program, and the availability of credit under the program.
12
Specifi c concerns that the Act directs
HUD to report on are up-front costs to borrowers, mortgage insurance premiums (“MIPs”), and margin rates charged under the HECM program.
13
Senators McCaskill and Kohl introduced the Reverse
Mortgage Proceeds Protection Act (S. 2490) (the
“Reverse Mortgage Act”) on December 12, 2007.
This Act addresses two major concerns that Senators
McCaskill and Kohl emphasized during the recent
Senate Special Committee on Aging’s reverse mortgage hearing:
Aggressive marketing tactics that convince seniors to obtain reverse mortgages, or expensive fi nancial products along with reverse mortgages, even when these products may be inappropriate or unnecessary; and
The underfunding of mandatory HECM counseling.
Aggressive Marketing Tactics
Prohibit the Required Purchase of an
Annuity. The Reverse Mortgage Act aims to address concerns regarding the sale of fi nancial products such as annuities along with reverse mortgages that are unnecessary or seriously ill-suited to the consumer. The
December 12 th Special Committee hearing emphasized harms associated with coupling annuities and reverse mortgages, but Senators and panel participants also mentioned concerns about the simultaneous sale of longterm care insurance, life insurance and other investment products.
14
To address this concern, the Reverse Mortgage
Act would require HUD to implement new regulations that would prohibit HECM lenders from requiring seniors to purchase an annuity with the proceeds of a reverse mortgage.
15
Tighten Rules on Mandated Counseling.
The Reverse Mortgage Act also would amend the HECM statute to specify that the mandated third party counseling for HECM borrowers must be obtained from a person or entity that is “not a reverse mortgage lender, servicer, or investor, or an entity engaged in the sale of annuities, investments, longterm care insurance, or any other type of fi nancial or insurance product.” 16 The statute currently requires only that the counselor not be a “lender.” 17 As discussed further below, counseling centers must be certifi ed by
HUD to provide counseling, not individual counselors. The Reverse Mortgage Act would not change the certifi cation requirements.
Require HUD to Issue Additional Consumer
Protection Regulations. The Reverse
Mortgage Act also would require HUD, within six months of the Act’s enactment, to issue regulations “to help protect elderly homeowners from the marketing of fi nancial and insurance products not in the interest of such homeowners, including the marketing or sale of an annuity as a condition of obtaining any [HECM].” 18 The Act provides no further guidance on the types of consumer protection regulations that HUD should issue.
Underfunding of Mandatory
HECM Counseling
During the reverse mortgage hearing, the Special
Committee on Aging expressed serious concerns about the inadequacy of resources to fund consumer counseling that is mandated prior to the consumer entering into a HECM.
19
To address this problem, the
Reverse Mortgage Act would allow HUD to use the
MIP (which fi nances FHA insurance of HECMs) to help pay for independent counseling services.
20
January 2008 | 2
Mortgage Banking & Consumer Credit Alert
In the December 12 th hearing, Senator McCaskill pointed out that HUD has set aside $3 million for
HECM counseling, yet one of the largest HECM counseling agencies expects to conduct 240,000 counseling sessions next year. At $100 per session, the shortfall would be over $20 million.
21
Currently, lenders are fi lling in the gap by paying for the counseling, and the Special Committee expressed concerns that this compromises the independence of the counselors. This in turn increases the risks to seniors of taking on fi nancial obligations ill-suited or even ruinous to them.
22
During the recent reverse mortgage hearing, Margaret
Burns, director of the FHA’s Single Family Program
Development, testifi ed that HUD is already in the process of developing new counseling protocols and will release the proposed regulations this spring.
According to Ms. Burns, HUD will tighten standards on HUD-certifi ed HECM counseling organizations by requiring that they be nonprofi t, independent
(from lender affi liations in particular), and objective organizations.
23
Further, she stated that standards will be imposed on individual HECM counselors for the fi rst time counseling organizations, not individual counselors).
HUD is considering requiring individuals who wish to be HECM counselors to undergo training and pass an examination. HUD would also like to require that in each consumer counseling session, counselors follow a specifi c set of questions that leads them through a range of topics designed to assess whether a
HECM is suitable for the consumer and whether any inappropriate fi nancial products are being offered in tandem with the HECM.
24
In the coming months, lenders and others in the mortgage industry interested in the market for reverse mortgages and similar products will want to watch legislative and regulatory developments on both the federal and state levels. Below is a status update on the House and Senate FHA reform bills and the
Senate’s Reverse Mortgage Act, as well as a preview of several possible arenas for reverse mortgage policy changes.
Reconciliation of the House and Senate
Versions of FHA Reform Bills (H.R. 1852;
S. 2338) . As noted, the House of Representatives passed companion FHA legislation (H.R. 1852) in September 2007. The House and Senate bills were not reconciled for fi nal passage in 2007, but a conference committee is expected to report a fi nal bill early in 2008. The House version is similar to S. 2338 on the reverse mortgage front. Among other measures, the House version eliminates the cap on the number of HECMs that FHA may insure each year. In addition, H.R. 1852 allows
FHA to insure HECMs that are used to purchase homes, directs HUD to establish new origination fee limits, and requires HUD to study and report to Congress on the impact of reducing the MIP for
HECMs.
25
The Reverse Mortgage Proceeds Protection Act
(S. 2490) . The reverse mortgage bill introduced in the Senate by Senators McCaskill and Kohl was referred to the Senate Committee on Banking,
Housing, and Urban Affairs. The Committee is expected to take up consideration of the bill early in 2008. There is currently not a companion
House bill.
Lifting the HECM Cap .
Both the Senate and House versions of the FHA reform bill would eliminate the annual cap on the number of HECMs that lenders may make (currently 275,000). Senators Tom Coburn,
McCaskill and other policymakers have expressed concerns about lifting the cap until more information is available about the fi nancial impact of doing so,
26
funding for mandatory borrower counseling is increased, and stronger consumer protections are in place.
27
Lower Costs .
As noted, the Senate FHA
Modernization Act proposes reducing HECM origination fees. It also requires HUD to report to
Congress on the impact of lowering costs and fees of
HECMs—presumably because Congress intends to consider further lowering costs to reverse mortgage borrowers. In the recent reverse mortgage hearing,
Senators expressed concerns about whether lowering the MIP could jeopardize the actuarial soundness of the HECM insurance program.
28
Policymakers have suggested that lifting the cap on the number of
HECMs that can be made annually could facilitate lowering MIPs by creating a larger pool for premium-
January 2008 | 3
Mortgage Banking & Consumer Credit Alert collection, but Congress has indicated that it would like further study of this issue before acting.
29
Referral Arrangements .
The reverse mortgage hearing also highlighted Congress’s concern with the relationships among lenders and various types of fi nancial agents, particularly insurance agents offering annuities.
30
Senators and panel participants suggested that these relationships can create fi nancial incentives for lenders and agents to promote inappropriate and expensive products for seniors. No specifi c measures for addressing this concern were mentioned other than improving consumer counseling, but the hearing on
December 12 th suggested that Congress is interested in monitoring these relationships and could impose express restrictions if necessary. It is also possible the
HUD may attempt to address these concerns through regulations.
Suitability Criteria .
Testimony and Senators’ comments at the December 12 th hearing also suggested that policymakers may consider imposing criteria for reverse mortgage loans to ensure that seniors obtain reverse mortgages only if they are appropriate.
31
Senators and panel participants compared the boom in reverse mortgages, which are much more expensive than most “forward” mortgages, to the former popularity of subprime mortgages. To avoid a similar market meltdown in the reverse mortgage industry, hearing participants specifi cally discussed requiring consumer counselors to cover specifi c issues aimed at determining the appropriateness of a HECM for a particular borrower. As noted, Ms. Burns of
HUD testifi ed that HUD plans to incorporate these procedures in regulations due out next spring.
Long-Term Care Insurance .
In 2000, Congress passed amendments to the HECM program that would have permitted borrowers to waive the initial mortgage premium if all of the proceeds of the reverse mortgage were used to fund long-term care insurance.
32
HUD issued proposed regulations to implement the legislation, but received negative comments and determined not to issue fi nal regulations to implement the law.
33
Reverse mortgage hearing comments and testimony indicated that policymakers may be interested in clarifying permissible practices and borrower incentives related to the sale of long-term care insurance with reverse mortgages.
Proprietary Products .
Proposed legislation (both the Senate FHA Modernization Act and the Reverse
Mortgage Act) and impending HUD regulations are not aimed at proprietary reverse mortgage products— reverse mortgages that are not insured by HUD and not subject to mandatory counseling under federal law.
At the same time, however, the number of proprietary reverse mortgage and related products is growing.
Indeed, Mr. Don Redfoot of AARP testifi ed to the
Senate Special Committee on Aging that the AARP encourages lenders to develop new reverse mortgage products, including reverse mortgage products with lower loan limits and costs for borrowers with more modest fi nancing needs.
34
Policymakers appear to be concerned about reverse mortgages, and could turn their attention to proprietary products in 2008. Lenders and others in the reverse mortgage industry should watch legislation that reaches beyond HECMs, but potentially model certain
HECM program amendments.
State Law .
State legislatures and regulatory agencies are already responding to the remarkable rise of reverse mortgage lending. States with housing counseling requirements for reverse mortgage loans include, among others, New York, Illinois, and
Massachusetts.
35
In California, reverse mortgage lenders must refer a prospective borrower to a housing counseling agency for counseling and obtain a certifi cation that the borrower received the required counseling prior to accepting a fi nal application for a reverse mortgage or assessing any fees.
36
The
California rules require lenders to give each borrower a list of at least fi ve housing counseling agencies approved by HUD and at least two agencies that can provide counseling by telephone.
37
Statutes requiring specifi c authority to offer or make reverse mortgages are also in place in certain states, such as Hawaii
38
and North Carolina,
39
and other states may well follow suit. In addition, servicers and purchasers of reverse mortgage loans should be attentive to possible state enactments of authorization requirements for servicing, funding, and purchasing reverse mortgage loans.
Regarding the sale of annuities, it would be no surprise if states follow the lead of states such as California to restrict the sale of annuities with reverse mortgage
January 2008 | 4
Mortgage Banking & Consumer Credit Alert loans. California prohibits requiring the purchase of an annuity as a condition of obtaining a reverse mortgage loan.
40
This law also prohibits a reverse mortgage lender or broker from offering an annuity to the borrower or referring the borrower to anyone for an annuity purchase prior to the loan closing or before the borrower’s right to rescind the loan expires.
41
4 H.R. 1852 (110 th Cong.).
5 § 112(a).
8 § 112(c).
In addition, certain state and local “high cost” loan laws include reverse mortgages in the defi nition of
“high cost” loan (provided the reverse mortgages meet applicable points and fees or APR/interest threshold).
These laws include “high cost” statutes in Arkansas,
Illinois (including local laws in Chicago and Cook
County), and Utah.
With the growth of the reverse mortgage market, state legislatures and regulatory agencies can be expected to continue examining reverse mortgages to propose incentive programs that enhance the availability and utility of reverse mortgages, as well as strengthen consumer protections. In 2007, legislation to facilitate or regulate reverse mortgage legislation was introduced (but has not yet passed) in a number of states, including Colorado,
42
Minnesota,
43
New
Jersey,
44
and New York.
45
* * * * *
If you have any questions or would like more information, please contact Steve Kaplan,
202.778.9204,
,
Nanci Weissgold, 202.778.9314,
, or Lorna Neill, 202.778.9216,
.
9 The full amount of the origination fee that can be charged to the borrower and fi nanced in the loan is capped at the greater of $2,000 or 2% of the maximum claim amount on the
HECM loan. The maximum claim amount on the HECM loan currently is the lesser of the appraised value of the property or the maximum mortgage amount for a one-family residence that HUD will insure in an area under Section 203(b)(2) of the
National Housing Act (which, again, the FHA Modernization
Bill proposes to change to the government-sponsored conventional single-family loan cap, currently set at $417,000).
See 24 C.F.R. § 206.31(a)(1); HUD Handbook 4235.1 REV-1, ¶
1-4(A)(2); Mortgagee Letters 2006-07, 2006-04, and 2000-10.
10 See S. 2338 (110 th Cong.), § 112(d).
11 See id.
12 See id.
13 See id.
14 See Hearing on Reverse Mortgages , Comments of Sen.
McCaskill; Testimony of Prescott Cole (California Advocates for Nursing Home Reform), Carol Anthony, Don Redfoot
(AARP).
15 See S. 2490 (110 th Cong.), § 2.
16 See id.
17 See 12 U.S.C. § 1715z-20(d)(2)(B).
18 See S. 2490 (110 th Cong.), § 2.
19 See Reverse Mortgage Hearing , Comments of Sen.
McCaskill.
20 See S. 2490 (110 th Cong.), § 2.
21 See Reverse Mortgage Hearing , Comments of Sen.
McCaskill.
22 See id.
1 See Hearing on Reverse Mortgages before the U.S.
Senate Special Committee on Aging , 110 th Cong. (Dec. 12,
2007) (“Reverse Mortgage Hearing”). The Reverse Mortgage
Hearing included the testimony of representatives from the
Department of Housing and Urban Development (“HUD”),
AARP, California Advocates for Nursing Home Reform, James
B. Nutter & Company (retail and wholesale reverse mortgage lender), and the daughter of a victim of predatory reverse mortgage lending practices.
2 S. 2490 (110 th Cong.), Reverse Mortgage Proceeds
Protection Act (introduced December 12, 2007).
3 S. 2338 (110 th Cong.), FHA Modernization Act (passed by U.S. Senate on December 14, 2007).
23 See id.
, Testimony of Margaret Burns.
24 See id.
25 See H.R. 1852 (110 th Cong.), § 20.
26 See Bill Swindell, “Senate Passes FHA Bill to Calm Roiled
Housing Market,” National Journal Group, Inc.
(discussing
Sen. Coburn’s call for a Government Accountability Offi ce study on the impact of lifting the HECM cap).
27 See Hearing on Reverse Mortgages , Comments of Sen.
McCaskill.
January 2008 | 5
Mortgage Banking & Consumer Credit Alert
28 See id.
, Comments of Senators Smith and Kohl.
29 See H.R. 1852 (110 th Cong.), § 20.
30 See Hearing on Reverse Mortgages , Comments of Sen.
McCaskill (in particular).
31 See id., Testimony of Margaret Burns (HUD), Prescott Cole
(California Advocates for Nursing Home Reform), Comments of Senators Kohl and McCaskill.
32 See American Homeownership and Economic Opportunity
Act of 2000, Pub. L. No. 106-569, § 201.
33 See Hearing on Reverse Mortgages , Testimony of Margaret
Burns.
34 See id.
, Testimony of Don Redfoot.
35 See, e.g.
, N.Y. Real Prop. Law §§ 280(g), 280-a(j); 205
ILCS 5/6.1(e); Mass. General Laws c. 167E, § 7(e). Another example is Mont. Admin. R. § 8.111.403 (for loans made by the state board of housing pursuant to Mont. Code Ann., § 90-6-501 et seq.
).
36 See Cal. Civ. Code § 1923.2(j), (k).
37 See id.
38 See Haw. Rev. Stat. § 506-10. Specifi cally, this provision prohibits any person, other than a state or federally chartered or licensed lender, from offering reverse mortgage loans. Id.
The statute narrowly restricts the meaning of “reverse mortgage loan,” however, defi ning it to exclude a loan: (1) insured by
HUD; (2) intended for sale to Fannie Mae or Freddie Mac; or
(3) for which mortgage counseling is required under other state or federal laws. Id.
For the small set of reverse mortgage loans to which Hawaii’s mortgage statute applies, the statute does not further identify what Hawaii license would be needed, whether a license from any state would be suffi cient, or whether HUD approval would be acceptable for a “federally licensed lender.”
39 See N.C. Gen. Stat. § 53-258. North Carolina’s Reverse
Mortgage Act prohibits any nonexempt person or entity from making reverse mortgage loans without being approved by the state as an authorized reverse mortgage lender. See id.
Mortgage lenders licensed under the North Carolina Mortgage
Lending Act, id. §§ 53-243.01 et seq.
, must be separately authorized under the Reverse Mortgage Act before making reverse mortgage loans. The following types of entities are exempt from applying for authorization to engage in reverse mortgage lending, although they may request written confi rmation of their authorization from the Commissioner of Banks: a bank, savings institution, or credit union formed under the laws of North Carolina, any other state, or the United
States; or a wholly owned subsidiary of such an entity. See id.
§ 53-258.
40 See Cal. Civ. Code § 1923.2(i).
41 See id.
42 See S.R. 8 (CO 2007) (passed the Colorado Senate on May
2, 2007).
43 See H.F. 1401 (MN 2007) and S.F. 196 (referred to committee).
44 See S.B. 2186 (NJ 2007) and A.B. 2942 (NJ 2007) (referred to committee).
45 See S.B. 4061 (NY 2007), A.B. 4735 (NY 2007), A.B. 6720
(NY 2007), S.B. 1753 (NY 2007), A.B. 2551 (NY 2007), S.B.
1189 (NY 2007), S.B. 642 (NY 2007), and A.B. 822 (NY 2007)
(referred to committee).
January 2008 | 6
Mortgage Banking & Consumer Credit Alert
K&L Gates’ Mortgage Banking & Consumer Finance practice provides a comprehensive range of transactional, regulatory compliance, enforcement and litigation services to the lending and settlement service industry.
Our focus includes fi rst- and subordinate-lien, open- and closed-end residential mortgage loans, as well as multi-family and commercial mortgage loans. We also advise clients on direct and indirect automobile, and manufactured housing fi nance relationships. In addition, we handle unsecured consumer and commercial lending. In all areas, our practice includes traditional and e-commerce applications of current law governing the fi elds of mortgage banking and consumer fi nance.
For more information, please contact one of the professionals listed below.
LAWYERS
Boston
Irene C. Freidel
Stephen E. Moore
Stanley V. Ragalevsky
Nadya N. Fitisenko
Brian M. Forbes
Los Angeles
Thomas J. Poletti
Miami
Paul F. Hancock
New York
Elwood F. Collins
Steve H. Epstein
Drew A. Malakoff
Thomas C. Russler
San Francisco
Jonathan Jaffe
Erin Murphy
Seattle
Holly K. Towle
Washington, D.C.
Costas A. Avrakotos
Melanie Hibbs Brody
Eric J. Edwardson
Steven M. Kaplan
Phillip John Kardis II
Rebecca H. Laird
Laurence E. Platt
Phillip L. Schulman
H. John Steele
Ira L. Tannenbaum
Nanci L. Weissgold
David L. Beam
Emily J. Booth
Krista Cooley
David Keith Gaston bruce.allensworth@klgates.com irene.freidel@klgates.com stephen.moore@klgates.com stan.ragalevsky@klgates.com nadya.fi tisenko@klgates.com brian.forbes@klgates.com thomas.poletti@klgates.com paul.hancock@klgates.com elwood.collins@klgates.com steve.epstein@klgates.com drew.malakoff@klgates.com tom.russler@klgates.com jonathan.jaffe@klgates.com erin.murphy@klgates.com holly.towle@klgates.com costas.avrakotos@klgates.com melanie.brody@klgates.com eric.edwardson@klgates.com steven.kaplan@klgates.com phillip.kardis@klgates.com rebecca.laird@klgates.com larry.platt@klgates.com phil.schulman@klgates.com john.steele@klgates.com ira.tannenbaum@klgates.com nanci.weissgold@klgates.com david.beam@klgates.com emily.booth@klgates.com krista.cooley@klgates.com david.gaston@klgates.com
+1.617.261.3119
+1.617.951.9154
+1.617.951.9191
+1.617.951.9203
+1.617.261.3173
+1.617.261.3152
+1.310.552.5045
+1.305.539.3378
+1.212.536.4005
+1.212.536.4830
+1.216.536.4034
+1.202.536.4068
+1.415.249.1023
+1.415.249.1038
+1.206.370.8334
+1.202.778.9075
+1.202.778.9203
+1.202.778.9387
+1.202.778.9204
+1.202.778.9401
+1.202.778.9038
+1.202.778.9034
+1.202.778.9027
+1.202.778.9489
+1.202.778.9350
+1.202.778.9314
+1.202.778.9026
+1.202.778.9112
+1.202.778.9257
+1.202.778.9061
January 2008 | 7
Mortgage Banking & Consumer Credit Alert
Anthony C. Green
Laura A. Johnson
Kris D. Kully
David G. McDonough, Jr.
Lorna M. Neill
Staci P. Newman
Stephanie C. Robinson
Kerri M. Smith
Holly M. Spencer
Erin E. Troy
DIRECTOR OF LICENSING
Washington, D.C.
Stacey L. Riggin anthony.green@klgates.com laura.johnson@klgates.com kris.kully@klgates.com david.mcdonough@klgates.com lorna.neill@klgates.com staci.newman@klgates.com stephanie.robinson@klgates.com kerri.smith@klgates.com holly.spencer@klgates.com erin.troy@klgates.com stacey.riggin@klgates.com
REGULATORY COMPLIANCE ANALYSTS
Washington, D.C.
Dameian L. Buncum
Nancy J. Butler
Teresa Diaz
Jennifer Early
Marguerite T. Frampton
Robin L. Gieseke
Angela M. Gonzalez
Joann Kim
Brenda R. Kittrell
Dana L. Lopez
Jeffrey Prost dameian.buncum@klgates.com nancy.butler@klgates.com teresa.diaz@klgates.com jennifer.early@klgates.com marguerite.frampton@klgates.com robin.gieseke@klgates.com angela.gonzalez@klgates.com joann.kim@klgates.com brenda.kittrell@klgates.com dana.lopez@klgates.com jeffrey.prost@klgates.com
+1.202.778.9893
+1.202.778.9249
+1.202.778.9301
+1.202.778.9207
+1.202.778.9216
+1.202.778.9452
+1.202.778.9856
+1.202.778.9445
+1.202.778.9853
+1.202.778.9384
+1.202.778.9202
+1.202.778.9093
+1.202.778.9374
+1.202.778.9852
+1.202.778.9291
+1.202.778.9253
+1.202.778.9481
+1.202.778.9369
+1.202.778.9421
+1.202.778.9049
+1.202.778.9383
+1.202.778.9364
K&L Gates comprises multiple affi liated partnerships: a limited liability partnership with the full name Kirkpatrick & Lockhart Preston Gates
Ellis LLP qualifi ed in Delaware and maintaining offi ces throughout the U.S., in Berlin, and in Beijing (Kirkpatrick & Lockhart Preston Gates
Ellis LLP Beijing Representative Offi ce); a limited liability partnership (also named Kirkpatrick & Lockhart Preston Gates Ellis LLP) incorporated in England and maintaining our London offi ce; a Taiwan general partnership (Kirkpatrick & Lockhart Preston Gates Ellis) which practices from our Taipei offi ce; and a Hong Kong general partnership (Kirkpatrick & Lockhart Preston Gates Ellis, Solicitors) which practices from our Hong Kong offi ce. K&L Gates maintains appropriate registrations in the jurisdictions in which its offi ces are located.
A list of the partners in each entity is available for inspection at any K&L Gates offi ce.
This publication/newsletter is for informational purposes and does not contain or convey legal advice. The information herein should not be used or relied upon in regard to any particular facts or circumstances without fi rst consulting a lawyer.
Data Protection Act 1998—We may contact you from time to time with information on Kirkpatrick & Lockhart Preston Gates Ellis LLP seminars and with our regular newsletters, which may be of interest to you. We will not provide your details to any third parties. Please e-mail london@klgates.com if you would prefer not to receive this information.
©1996–2008 Kirkpatrick & Lockhart Preston Gates Ellis LLP. All Rights Reserved.
January 2008 | 8