2010
03.11

MMRecap for March 8

The benchmark 10-year note barely moved the first four days of last week.  Uncertainty about what the Fed will do, a mixed group of economic reports, conflicting signals about the direction of the economy and caution prior to the February employment left the 10-year yield, which moves in the opposite direction of price, right around 3.60% — until Friday, that is.

The jobs report showed 36,000 workers dropped from nonfarm payrolls last month — far less than expected but more than the 20,000 lost in January.  The unemployment rate held at 9.7%, but many had expected an increase.

Because this report was better than predicted, selling in Treasuries was aggressive, sending prices down and yields to their highest levels in more than a month.  Friday’s report could indicate that the employment picture is improving, which would reduce the need for risk-free investments.  This, of course, would push yields up.

March began with the ISM index on manufacturing for February.  It fell to 56.5 from 58.4, with declines in new orders and productivity, but employment rose to 56.1 from 53.3.  Separately, construction spending in January fell 0.6%, an improvement over the previous 1.2% decline.

Personal spending in January rose 0.5%, while income edged up 0.1%, with the amount spent on goods rising almost 1%.  The core rate, a key inflation indicator, was flat.  Also in play was word of an impending bailout package that would ease Greece’s debt problems and erase the need for some safe-haven buying.

No releases were scheduled on Tuesday, but Wednesday’s better-than-expected ISM reading on the service sector put some pressure on Treasuries.  It rose to 53 — its highest level since December 2007.  Most components posted gains, except for ‘prices paid,’ which was more good news re inflation.

The Fed beige book, which looks at the economy in the nation’s 12 federal districts, showed the economy improving in nine of those districts.  Lending remains tight, however, and employment was showing few signs of improvement.

Thursday’s first-time unemployment claims for the week ended Feb. 27 fell unexpectedly by 29,000 to 469,000, while continuing claims dropped to 4.5 million.  This ignited some selling, but a 7.6% decline in pending home sales in January brought the buyers back.  A 1.0% increase was expected.

Revised 4thquarter productivity rose to 6.9% from 6.2%, while unit labor costs were revised downward to 5.9% from -4.4%.  High productivity without high costs is another sign that inflation is not a present threat.  Also, factory orders in January rose 1.7% from 1.5% in December.

Lower mortgage rates during the week ended Feb. 26 lit a fire under home buyers and refinancers, according to the Mortgage Bankers Association.  Purchase applications rose 11.7%, while refis were up a whopping 17.2%.

This week doesn’t get interesting until Friday, except for Thursday’s first-time jobless claims for the week ended March 6.  And who knows which way that one will go?

The U.S. trade deficit for January is also due, but it is a nonfactor when it comes influencing the markets.  The same holds true for January’s wholesale inventories.  They’re predicted to rise 0.2% from -0.8% in December, but the release will likely go unnoticed.

Friday has the week’s biggest report — retail sales for February.  Analysts expect sales to fall 0.1% versus a 0.5% January gain.  When autos are excluded, sales should be flat as opposed to the previous 0.6% gain.  Treasuries would welcome this because the economy will not move forward without the support of consumer spending.

It’s possible that predictions could be revised, however.  The extraordinary sales figures posted by Ford and GM last Tuesday, and Thursday’s healthy reports on same-store-sales by major retailers could change these numbers.  But retail sales encompass more than car sales and how well the malls are doing.

The preliminary consumer sentiment report for March from Reuters/The University of Michigan is also due, but analysts are expecting the smallest possible increase.  They’re saying it should rise to 73.7 from 73.6.

The final report of the week is business inventories for January.  They are expected to increase by 0.1% from a 0.2% decline in December. T his report will be ignored, with most of the effort geared toward dissecting retail sales data.

2010
03.11

Continued High Negative Equity and Home Value Declines in 2010

Home values across the country declined again in the fourth quarter of 2009, as the Zillow Home Value Index fell 5 percent year-over-year, and 0.5 percent quarter-over-quarter, to $186,200.  That marked the 12th consecutive quarter of year-over-year declines, according to the fourth quarter Zillow Real Estate Market Reports.

Despite home value declines seen across most of the country throughout 2009, some markets experienced what appeared to be a bottom in home value declines, or even increases in home values during the year.  However, the fourth quarter of the year brought signs that the fledgling recovery of home values in many of these markets is slowing again.  If the declines are sustained, the result will be a “double dip” in home values, defined as two periods of sustained declines in home values separated by a brief period of stabilization or recovery.

One in five, or 29 of the 143 markets tracked by Zillow, showed at least five consecutive month-over-month increases in home values during 2009 before beginning to flatten or fall again in the second part of the year.  These markets include the Boston metropolitan statistical area (MSA), the Atlanta MSA and the San Diego MSA.

Home values in an additional 29 markets, including the Los Angeles and New York MSAs, increased on a month-over-month basis each month throughout the fourth quarter.  However, the rate of increase slowed from November to December in 21 of those markets, and several appear likely to experience several months of sustained decline in early 2010.

The percent of single family homes with mortgages in negative equity was essentially flat from the third to the fourth quarter, changing from 21 percent in Q3 to 21.4 percent in Q4.  This comes after a decrease in negative equity from the second quarter’s 23 percent.

The number of homeowners losing their homes to foreclosure across the country reached a peak in December, with more than one in every thousand homes being foreclosed — a number not reached since Zillow began recording national foreclosure data in 2000.

“While we have seen strong stabilization in home values during 2009, there are clear signs that they will turn more negative in the near-term,” said Zillow Chief Economist Stan Humphries.  “What we saw in mid-2009 was a brief respite from a larger market correction that has not yet run its course.  The good news is that, for those markets that will see a double dip in home values before reaching a definitive bottom, this second dip will not be a return to the magnitude of depreciation seen earlier, but rather will look more like a modest aftershock of the earlier downturn.

“The recent stabilization owed a lot to policy support in the form of tax credits, lower interest rates and increased Federal Housing Administration lending.  The remaining correction in home values we’ll see in the first half of this year is a function of market fundamentals, such as the increasing flow of foreclosures, high levels of inventory in the market and a probable decrease in demand as the impact of the tax credit wanes and mortgage rates rise.  While the next few months are likely to bring further home value declines in most markets, we do expect to see a national bottom in home prices by the middle of this year.  Thereafter, home values are likely to bounce along the bottom with real appreciation remaining negligible for some time.”

Foreclosure re-sales across the country remained high, making up more than one-fifth (20.3 percent) of all U.S. home sales in December.  Foreclosure re-sales also made up the majority of sales in several MSAs, including the Merced, Calif. MSA (68.3 percent), the Las Vegas MSA (64 percent) and the Modesto, Calif. MSA (62 percent).  Additionally, 28.5 percent of home sales nationwide sold for less than what the seller originally paid.

Several markets across the country showed positive longer-term appreciation.  Home values increased year-over-year in 27 of 143 markets and remained flat in 15.

The Boston MSA was the largest area with year-over-year appreciation, despite its more recent downturn in home values.  The area’s Zillow Home Value Index rose 1.9 percent in 2009.  Home values in the Boston area rose for eight months in 2009, which outweighed the recent declines.

The full national report, in its interactive format, is available at www.zillow.com/local-info.  Additionally, in most areas data is available at the state, metro, county, city, ZIP and neighborhood level.

 

By: www.zillow.com

2010
03.09

An Article of Interest

Great Time to Invest in Rental Property

If you’re thinking about investing in a rental property, experts say low home prices combined with low interest rates make this the best time in years to become a real estate investor.

What’s more, the real estate market is starting to recover: U.S. houses lost $489 billion in value during the first 11 months of 2009, but that was significantly lower than the $3.6 trillion lost during 2008, according to real estate Web site Zillow.com,

“We haven’t seen home prices this low in so many years — coupled with the rates being so low,” says Jill Sjolin, an agent with Windermere Real Estate in Woodinville, Wash., who specializes in investment properties.  “When the money is cheap to borrow and the houses are cheap to buy, it’s absolutely the best time to invest.”

While the timing may be right, the following five tips can help first-time investors take advantage of what might be the opportunity of a lifetime.

1) Know your options.  Since all investment properties are not the same, it’s important to determine what type of property fits your strategy, says Harrison Merrill, chief executive officer of Merrill Trust Group, a real estate investment company based in Atlanta.  Do you want to become a landlord or would you rather restore and resell properties?  Are you interested in apartment buildings and other commercial real estate or buying land that can be developed?  First-time real estate investors may want to start with residential housing, since commercial real estate and land development still face challenging market conditions, Merrill says.

2) Partner with experience.  First-time investors should find a Realtor experienced with investment property deals who can help you locate promising properties.  “Look for relational brokers who expect to do business with you again and therefore are going to be much more careful with what they recommend,” says Merrill. 

A second option is to collaborate with a more experienced real estate investor and close a deal together.  In this economy, an experienced real estate investor may be willing to work with you in exchange for the capital you can provide, giving you the opportunity to glean investment knowledge and experience firsthand, Merrill says.

Even if you don’t collaborate with other real estate investors, talk to them about pitfalls they’ve experienced.  “Go down to the general district court in your area and listen to some landlord/tenant cases so you can get a sense of what kind of challenges landlords face,” says Jeffrey Taylor, author of “The Landlord’s Kit.”

3) Look for the right location.  If you buy a property with hopes of renting it out, location is key.  Homes in high-rent or highly populated areas are ideal; stay away from rural areas where there are fewer people and a small pool of potential renters, suggests Sjolin.  Also, look for homes with multiple bedrooms and bathrooms in neighborhoods that have a low crime rate.  “Renters gravitate to a safe neighborhood, and if they have kids they will want a good school district,” Sjolin says.

Think about potential selling points for your property.  If it’s near public transportation, shopping malls or other amenities, it will attract renters, as well as potential buyers if you decide to sell later.  The more you have to offer, the more likely you are to please potential renters, says Sjolin.

4) Have capital lined up.  Speak to potential lenders or even a financial planner about whether you have enough assets to handle the ups and downs that could come with investing.  Even if you plan to rent out the property, count on paying the mortgage whenever there’s a vacancy.  “If you can have about six months of mortgage payments saved up, it’s there if you need it, and you can use that money for repairs,” says Sjolin.  Even if you’re planning to fix up a home and sell it, you may end up holding onto it for several months in the current market, Sjolin adds.

5) Build a supporting cast.  Don’t wait until a rental property needs repairs to find someone to handle them.  “Line up maintenance individuals who can take care of the different challenges that occur so you can simply call the person when a particular issue comes up,” says Taylor. 

Other sources you may want to have relationships with are an attorney to consult with on tenant issues, a property management firm to handle the day-to-day rental affairs and an accountant to help you understand the tax ramifications of investing.  The more support you have, the better you will be able to handle the problems that come your way.

Whatever you do, understand that buying investment property is an entirely different experience than buying your primary residence.  “When you go to buy your own home, you usually have emotions in it,” says Sjolin.  “When you go to buy an investment property, you need to put all that aside and ask, ‘What makes sense?’”

 

By: Tamara E. Holmes, www.bankrate.com

2010
03.08

Guaranteed Rate Report – Sims – March 8, 2010

Market news for the week.

2010
03.07

10 Questions for Homebuyers Who Want to Go Green

For homebuyers, green is fast becoming a priority — whether it’s because they want to reduce their energy costs, minimize their carbon footprint or improve indoor air quality.

Here are 10 questions that prospective buyers or renters ought to ask to find out how green a house or apartment is.

1. How big is it?

The bigger the home, the more energy it uses.  The U.S. Green Building Council considers a “neutral size” home — basically what most people need, without what might be considered luxury space — to be 900 square feet for a one-bedroom home, 1,400 square feet for two bedrooms and 1,900 square feet for three bedrooms.  A 100% increase in the size of the home adds anywhere from 15% to 50% to energy use.

2. Where is it?

Can you walk to public transportation?  Are there sidewalks or easy places to walk in the neighborhood so you don’t always have to drive?  How close are shopping centers and other places you would frequent?  The Web site walkscore.com rates the walkability of cities, neighborhoods and individual addresses and shows the distances to stores, restaurants, schools and amusements.

3. How is it oriented?

South-facing windows can trim heating costs in the winter.  Shade from trees to the south and west can reduce cooling costs in the summer.

4. Is it well-insulated, and are doors and windows sealed tightly against air leaks?

The U.S. Energy Star Web site, energystar.gov, features a calculator to help determine how much insulation you need, based on your location.  To guard against air leaks, windows and exterior doors ideally should have an Energy Star rating, which indicates they meet a certain standard of efficiency in preventing the loss of heat in the winter and cooling in the summer.  You may be able to feel air leaks, or you can hire an energy auditor to conduct a “door blower test” — a big fan placed in a doorway sucks air out of the home, creating easily detectable drafts rushing in from outside wherever there’s a leak.

5. Has the indoor air quality been tested?

Well-insulated, well-sealed homes not only hold in heat and cooling, but also can retain toxins such as formaldehyde, mold, asbestos and lead.  A test will show whether any toxins are present in levels that exceed the safe maximums established by the Environmental Protection Agency.  You might also ask whether the home was constructed or renovated with nontoxic building materials and furnishings, such as low- and zero-emission paints.

6. If it’s an older home, have insulation, heating and cooling systems and appliances been upgraded?

Newer products are far more efficient than those bought several years ago.  Also, has higher-efficiency lighting been installed?

7. How efficient is the water usage?

Are the kitchen and bathrooms equipped with water-efficient plumbing fixtures?  If it’s a house, does it have a water-conserving irrigation system for the grounds, and landscaping that minimizes the use of water?  It may also have a rainwater collection and storage system, particularly in drier areas where water is increasingly scarce and costly.

8. What’s on the roof?

A lighter-colored roof reflects more heat than a dark-colored roof, which absorbs heat, putting more strain on the cooling system.  Does it have skylights that let in natural light?

9. Where did the home’s materials come from?

Recycled or salvaged building materials reduce the home’s impact on the environment.  Also preferable are materials that are locally available, can be processed with less energy and water, are reusable or recyclable, are durable and are abundant in the environment.

10. Has it been certified green?

The U.S. Green Building Council, the Environmental Protection Agency and others offer ratings on homes, based on inspections by trained third-party professionals.

 

By: Sari Krieger, www.wsj.com

2010
03.02

Mon MMRecap for March 1

Last week began flat, but it turned out to be a good week for U.S. Treasuries.  Disappointing economic news, successful auctions, continued economic turmoil in Europe and another pledge from the Fed to keep interest rates low for an “extended period” kept buying in bonds steady to heavy.

On Tuesday traders learned that consumer confidence in February fell to 46 from a 16-month high of 56.5, igniting a huge rally.  Concerns about the economy and job prospects sent the index plunging far below the predicted 55.5, giving Treasuries their best day of the week.

They rallied again Wednesday when January new home sales plunged 11.2% to an annual rate of 309,000 units — the fewest since record-keeping began in 1963.  An abundance of foreclosures on the market and high unemployment were cited as key reasons for the downturn.

Fed chairman Ben Bernanke also addressed Congress and acknowledged that recovery had begun, but cited “jobs” as the main challenge.  He also said that economic recovery is not self-sustaining.  These statements were well received by Wall Street, which drew some money from Treasuries.

But bonds rallied once again on Thursday as first-time jobless claims rose by 22,000 to 496,000 for the week ended Feb. 20.  Some blamed the weather for the numbers, which were far higher than the expected 460,000.  Continued claims, people collecting benefits for more than one week, rose to 4.6 million.

Durable goods orders in January doubled expectations, rising 3%.  Aircraft accounted for the lion’s share of orders.  When transportation was excluded, orders fell 0.6%.  The unemployment numbers and fear that Greece may not be able to pay its debts sent investors fleeing to the safe haven of bonds.

Treasury yields edged down early Friday on a mixed bag of economic reports.  Existing home sales in January fell 7.2% to an annual rate of 5.05 million units, the lowest level in seven months.  The inventory of unsold homes rose to a 7.8-month supply.  Separately, the first revision of 4thquarter GDP edged up to 5.9% from 5.7%, indicating the economy is growing more quickly than expected.

The Chicago PMI of February manufacturing conditions rose to 62.6 from 61.5, but the University of Michigan’s final consumer sentiment survey for February edged down to 73.6 from 74.4, on jobs and the economy — the same concerns that affected the consumer confidence report.

Mortgage applications slowed during the week ended Feb. 19, according to the Mortgage Bankers Association.  Purchase applications were down 7.3% while refis tumbled 8.9%.

This week is busy, but it all leads up to Friday’s February employment report.  Analysts expect another 20,000 jobs to fall from nonfarm payrolls.  In addition, the unemployment rate, taken from a separate survey, could rise to 9.8% from 9.7%.  This would ignite buying in bonds.

In December the rate was 10% and a revised 150,000 jobs were lost.  Nevertheless, Treasuries should respond positively to the numbers, if they come in on target.  The answer to economic recovery is jobs, jobs, jobs.

The week begins with expected gains in personal spending and income for January.  Both should rise 0.4%, but core prices are expected to show only a 0.1% increase.  This indicates that inflation, an enemy of fixed-rate assets, is well under control.

Wednesday’s ISM index on February manufacturing conditions will make no waves if it falls to the expected 58.0 from 58.4.  A bigger drop, however, could rally Treasuries.  The afternoon release of the Fed beige book might also impact trading.  A report indicating weaker economic conditions in the 12 federal districts could boost Treasuries, while signs of strength would have the opposite effect.

Thursday’s firsttime jobless claims for the week ended Feb. 27 could influence trading, but recent volatility leaves uncertainty about which way it will go.  This report will be followed by a revision of 4thquarter productivity and costs.  The advance numbers showing a 6.2% increase in productivity and a 4.4% decline in costs should remain unchanged.

Factory orders for January are expected to increase 1.0%, but this will have little impact.  Pending home sales for January, however, could put pressure on bonds.  The NAR expects a 1.7% increase, which would be dwarf the 1% gain the previous month.

2010
03.02

The Future of Plastic: 5 Credit Trends for 2010

The CARD„Act goes into effect on Feb. 22 and with it come stronger consumer protections.  Banks will no longer be able to raise interest rates during the first 12 months after opening an account — or hike rates on pre-existing balances altogether.  Credit-card payments, if exceeding the minimum, will be allocated to the higher-rate balances first.  Monthly statements will become easier to understand and the ability to issue credit„cards to college students will be severely restricted.

But these new safeguards will come at a price.  Although card„issuers focused last year on making sure they’ll be in compliance with the new law, now they will have to figure out how to make money given the changes in their business, says Dennis Moroney, a research director at financial-services research group TowerGroup.  This “will be the year of transition for the banks,” he says.

Consumers have already gotten a hint of what’s to come.  As soon as President Obama signed the CARD Act into law last year, banks sprung into action, hiking interest rates across the board and switching their APR formulas from fixed to variable rates.  They’ve already found loopholes in the new law, including a creative way of charging a penalty APR as soon as a payment is one day late and continuing to implement the soon-to-be prohibited practice of double-cycle billing.

Here’s what else consumers can expect from their credit-card issuers in 2010.

1. Punishing inactivity

Using your credit cards wisely used to mean keeping your balances low relative to your available credit, and locking your cards in a drawer was deemed smart.  Today, the wise use of credit entails something entirely different: making sure those cards don’t stay in the drawer for too long.

As card issuers face growing restrictions in an economic environment that remains challenging, this year they will place an even stronger focus on inactive accounts, reducing credit„limits, introducing inactivity fees or closing them altogether, says Robert Hammer, the chief executive officer of R. K. Hammer, a bank-card advisory firm.  Why?  Inactive accounts are a losing proposition for card issuers: They’re not making any money off you from interest payments or interchange fees, but they have to spend money on printing and mailing you things like account notifications or statements.  More importantly, such accounts leave them open to the risk that you will lose your job, max out the card and leave the bank holding the bag.

To keep all your accounts active, Hammer recommends rotating your different cards each month.

2. Looking beyond credit scores

Just a few years ago, the main factors in determining your credit-card interest rate and credit„limit were your credit score and payment history.  Now, issuers take a lot more into account when evaluating their existing and prospective card holders’ risk profiles.  For example, living in an area with high unemployment or working in an industry where job security is volatile can prompt an issuer to reduce your credit limit or introduce an annual fee to your account, even if your credit and payment histories are spotless, says David Robertson, owner of the Nilson Report, which tracks credit-card industry trends.  “Six issuers control 80% of the market,” he says.  “They use very sophisticated programs and are able to slice and dice their portfolio in many ways.”

That said, using sophisticated analytics may cut both ways.  Issuers may become more lenient in their lending decisions with consumers who have only recently seen their credit hurt by the loss of a job or home.  “Joblessness took down a lot of people who were good, solidly middle-class, good-score customers,” Robertson says.  “The question will be, when this person gets a job again, will he return to their profile of an honest, trustworthy customer, but with a lower credit score?”

3. Chasing after college parents

College students used to be among card issuers’ most sought-after customers.  They tend to charge beyond their limited means and stay loyal to the first bank with which they do business.  What will happen once the CARD„Act prohibits them from marketing on campus and restricts their ability to issue cards to anyone under the age of 21?  Rather than offering free T-shirts or digital music players to college students, banks will start campaigning to their parents.  This year, parents can expect to receive more offers of co-signing a child’s credit„card, and many of them will likely tout “parental control” features like the ability to monitor and limit spending.

If you’re a college parent, make sure you are aware of the consequences and risks of co-signing a credit card.  You will be liable for any unpaid balance and, in the event of a late payment or other negative account activity, a stain on your own credit record.

4. Reinventing secured credit cards

Secured credit„cards fell out of favor years ago, when banks started targeting low- or no-credit consumers with so-called subprime credit cards which were loaded with fees and high interest rates.  But with the CARD Act restricting the amount of fees a bank can charge relative to the available credit„limit, subprime cards will all but disappear.  Millions of consumers have seen their credit damaged by bankruptcy or foreclosure and will need a new way to start rebuilding their credit.  One way subprime issuers will continue targeting that demographic will be to look back to secured credit cards, says Odysseas Papadimitriou, the chief executive of Evolution Finance Inc., which publishes CardHub.com, a credit-card comparison web site.

A secured credit card works just like any other card, but it requires the consumer to make a security deposit (usually a minimum of $200 or $300), which then equals their credit limit.  Do not confuse these cards with prepaid or debit cards, however: While the bank will keep your deposit (and in some cases even pay you interest on it), you still have to make at least minimum payments to be in good standing, or pay the balance in full to avoid paying interest.  Card activity is reported to the three major credit bureaus.

5. Introducing debit-card fees

Mindful of their budgets and frustrated with the plethora of fees associated with credit cards, many consumers are turning to debit.  They may soon be disappointed to find out that fees are making their way into debit„cards, as well, says TowerGroup’s Moroney.  “Debit cards are a very thin-margin product.  And with the changes in overdraft fees, the banks are going to start charging annual and other types of fees,” he says.

The cards most likely to be subject to an annual fee are debit cards that have rewards programs.  Another possibility: the introduction of fees for using your PIN at the point of sale.  That’s because banks charge merchants more for signature-based purchases.  (Some retailers, including Costco, now allow signing for debit purchases.  As the battle between retailers and issuers heats up, others may soon follow.)  If you are among the growing number of consumers who are shunning their credit cards and turning to debit, make sure you are familiar with your issuer’s PIN and signature policies.

 

By: Aleksandra Todorova, www.smartmoney.com

2010
03.01

See what Guaranteed Rate can do!  It’s so important to work with a lender that will provide you with excellent service and that is someone you can trust and count on.  It’s a bonus that we can still do so many things; even in today’s economy!  Call us today for a FREE mortgage consultation.  (See attachment with some of the available programs.)

Guaranteed Rate Newsletter – February 25, 2010

2010
02.27

I just posted a bunch of information on some of the new legislation that has passed in the last year.  Dating back to the beginning of last year is the HVCC – Home Valuation Code of Conduct rule regarding appraisals.  Then there is the MDIA – Mortgage Disclosure Information Act.  And, most recently the RESPA Reform. 

Please check everything out and let us know your thoughts on the governments changes!  The Lake Team and Guaranteed Rate is doing our VERY best to make sure that all of these transitions are done as seemlessly as possible.  Please feel free to forward this message to your friends, family, or co-workers.  It is very important that everyone is educated on this.  Whether you are looking to buy or sell – now or later; or even refinance; these new rules and regulations can impact you.

For more information please feel free to contact our office @ 847-470-3357 or laketeam@jeffreylake.com.  You can also view more on our blog @ www.mortgagesolutionsforgenerations.com or our Facebook page @ http://www.facebook.com/photo.php?pid=11243644&id=82934540577&saved#!/pages/Skokie-IL/The-Lake-Team-Guaranteed-Rate/82934540577.   

Jo Ann Theriault-Fazio
Vice President of Mortgage Lending
The Lake Team @ Guaranteed Rate

2010
02.23

RESPA Reform is the newest legislation to come out of Washington.  Attached is some information detailing what the reform calls for and changes. 

respa_reform