Thursday, January 27, 2011
Wednesday, January 26, 2011
Bank of America and Wells Fargo Most Sued Banks in 2010
http://www.dsnews.com/articles/bank-of-america-and-wells-fargo-most-sued-banks-in-2010-2011-01-25
A recent report by Institutional Risk Analytics (IRA) says Bank of America and Wells Fargo are two of the most sued financial service firms in the United States. IRA says that mortgage exposure is what is causing these two banks and others in similar situations to be embroiled in so many federal legal cases. In addition, the firm points to the added burden many of these companies are also facing in litigation that will not reach federal court, such as cases involving foreclosure practices.
Note Wells still showed a profit in 2010 and laid off people.
A recent report by Institutional Risk Analytics (IRA) says Bank of America and Wells Fargo are two of the most sued financial service firms in the United States. IRA says that mortgage exposure is what is causing these two banks and others in similar situations to be embroiled in so many federal legal cases. In addition, the firm points to the added burden many of these companies are also facing in litigation that will not reach federal court, such as cases involving foreclosure practices.
Note Wells still showed a profit in 2010 and laid off people.
Tuesday, January 25, 2011
Birds & Fish Dropping
http://gizmodo.com/5727206/all-the-mass-deaths-of-animals-plotted-on-a-map?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+gizmodo%2Ffull+%28Gizmodo%29&utm_content=Google+Reader
http://maps.google.com/maps/ms?msa=0&msid=201817256339889828327.0004991bca25af104a22b&ie=UTF8&ll=36.315125,-94.921875&spn=48.363953,87.890625&z=3&source=embed
Mainstream Explanations: These have included lightning, hail, mid-air collision, power lines, and New Year fireworks for the birds, and a disease for the fish. But this seems like a heck of a coincidence, and where are the roasted birds from a lightning strike?
Meteor showers: During this period of intense seasonal meteor shower, some people reported hearing sonic booms in the area that might have been an indication of a local shock wave.
New Madrid Fault Line: Could it be related to the recent earthquake activity along a fault line that runs along the mid-eastern section of the U.S.? Could it have dispersed pollutants into the water and atmosphere?
Government testing: Only certain species have been affected, but within the entire region. And some reports have indicated that the organs of the birds were liquefied -- could this implicate species-specific bio-weapons?
GMOs: There are other die-offs are happening across other species, such as bees and bats. Some think they could be poisoned by genetically modified plants.
Geoengineering: Could spraying in the area have caused this?
HAARP: Both birds and fish navigate in highly coordinated ways. Could the HAARP array off in Alaska have short-circuited their navigation systems? Or is it the result of electromagnetic pollution for other human devices?
Scalar Weapons: Some wonder if the cause is directed energy beam weapons deployed via satellite.
Project Blue Beam: Another theory is a sound generator weapon.
Geomagnetic and other Earth changes: The magnetic pole is moving. Add to this a dwindling magnetosphere and falling oxygen levels, plus an increase in sun activity and magnetic storms.
Update: A Wisconsin lab has apparently determined that the birds, at least, died of blunt force trauma.
http://maps.google.com/maps/ms?msa=0&msid=201817256339889828327.0004991bca25af104a22b&ie=UTF8&ll=36.315125,-94.921875&spn=48.363953,87.890625&z=3&source=embed
Mainstream Explanations: These have included lightning, hail, mid-air collision, power lines, and New Year fireworks for the birds, and a disease for the fish. But this seems like a heck of a coincidence, and where are the roasted birds from a lightning strike?
Meteor showers: During this period of intense seasonal meteor shower, some people reported hearing sonic booms in the area that might have been an indication of a local shock wave.
New Madrid Fault Line: Could it be related to the recent earthquake activity along a fault line that runs along the mid-eastern section of the U.S.? Could it have dispersed pollutants into the water and atmosphere?
Government testing: Only certain species have been affected, but within the entire region. And some reports have indicated that the organs of the birds were liquefied -- could this implicate species-specific bio-weapons?
GMOs: There are other die-offs are happening across other species, such as bees and bats. Some think they could be poisoned by genetically modified plants.
Geoengineering: Could spraying in the area have caused this?
HAARP: Both birds and fish navigate in highly coordinated ways. Could the HAARP array off in Alaska have short-circuited their navigation systems? Or is it the result of electromagnetic pollution for other human devices?
Scalar Weapons: Some wonder if the cause is directed energy beam weapons deployed via satellite.
Project Blue Beam: Another theory is a sound generator weapon.
Geomagnetic and other Earth changes: The magnetic pole is moving. Add to this a dwindling magnetosphere and falling oxygen levels, plus an increase in sun activity and magnetic storms.
Update: A Wisconsin lab has apparently determined that the birds, at least, died of blunt force trauma.
Judge Moonlighting
http://alm-editorial-us.msgfocus.com/c/1fuqoB0xSUPuT1AQHyv
In New York, a state judge can race motorcycles, coach basketball and captain a sightseeing boat without creating a conflict with his primary judicial role or compromising its dignity. Those are a few of the determinations made since prohibitions against judicial moonlighting were relaxed.
In New York, a state judge can race motorcycles, coach basketball and captain a sightseeing boat without creating a conflict with his primary judicial role or compromising its dignity. Those are a few of the determinations made since prohibitions against judicial moonlighting were relaxed.
What Does the Ibanez Decision Mean?
What Does the Ibanez Decision Mean?
19 January 2011
Article by Mintz Levin Real Estate Group
The following client alert is in response to the U.S. Bank v. Ibanez, decided by the Massachusetts Supreme Judicial Court on Friday, January 7, 2011.
The Massachusetts Supreme Judicial Court (SJC) announced its decision of the Ibanez case and ruled against the validity of foreclosure sales of two securitized mortgages. The case has important implications for all foreclosures in which the foreclosing party is not the original lender. Here are some particulars of the decision for your consideration.
1. A lender or servicer exercising the power of sale must be the holder of the mortgage by a complete chain of valid assignments. Ownership of the note alone does not confer a right to foreclose unless the mortgage so provides. The rule previously followed by some Massachusetts conveyancers—that ownership of the mortgage automatically follows ownership of the note—was rejected by the Court. The Court also rejected the banks' argument that their right to obtain an assignment of the mortgages (which was set forth in the securitization documents) gave the banks the right to foreclose.
2. A lender or servicer must be the holder of the mortgage when the power of sale is exercised. Back-dated assignments and assignments made after the exercise of the power of sale do not satisfy this requirement. Confirmatory assignments are effective only if they confirm a written assignment that was in existence when the power of sale was exercised.
3. An assignment of a mortgage in blank, that is, an assignment that does not name the assignee, is invalid.
4. A valid mortgage assignment need not be in recordable form and need not be recorded. An assignment of a pool of mortgages made in an unrecorded securitization document may be valid if the document meets the requirements of M.G.L., Chapter 183, Chapter 3 and if it specifically identifies the mortgages being assigned. The Court noted that the best practice is to record allmortgage assignments in the proper order.
5. The Ibanez decision does not address questions of New York law concerning transfers of securitized mortgages to bond trustees, nor does it address the validity of MERS (Mortgage Electronic Registration Systems) or of mortgage securitization in general. The banks lost because they could not produce valid assignments of the mortgages that they had purported to foreclose.
6. The Ibanez decision is based entirely on existing Massachusetts law and applies only to Massachusetts. Courts in other states that use judicial foreclosure or treat mortgages as liens rather than conveyances of legal title to real estate may reach different results on similar facts.
When foreclosing a mortgage in Massachusetts, we have recommended to our clients that ownership of both the note and mortgage be transferred of record to a single asset entity established by the lender for the purpose of foreclosing the mortgage and taking title to the property after the foreclosure sale. We have also recommended that lenders obtain a commitment for a new owner's policy of title insurance, which will insure the validity of the foreclosure sale and the validity of any assignments of the mortgage. The Ibanez decision confirms our belief in the soundness of this advice.
When drafting a mortgage for a loan, which may be securitized or which may become subject to some form of co-lending agreement (such as an A and B note structure), particular attention should be paid to the drafting of the power of sale clause. There should be no ambiguity as to who has the power to foreclose the mortgage if ownership of the note should become separated from legal title to the mortgage or if ownership of the debt should be split among several parties.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances
19 January 2011
Article by Mintz Levin Real Estate Group
The following client alert is in response to the U.S. Bank v. Ibanez, decided by the Massachusetts Supreme Judicial Court on Friday, January 7, 2011.
The Massachusetts Supreme Judicial Court (SJC) announced its decision of the Ibanez case and ruled against the validity of foreclosure sales of two securitized mortgages. The case has important implications for all foreclosures in which the foreclosing party is not the original lender. Here are some particulars of the decision for your consideration.
1. A lender or servicer exercising the power of sale must be the holder of the mortgage by a complete chain of valid assignments. Ownership of the note alone does not confer a right to foreclose unless the mortgage so provides. The rule previously followed by some Massachusetts conveyancers—that ownership of the mortgage automatically follows ownership of the note—was rejected by the Court. The Court also rejected the banks' argument that their right to obtain an assignment of the mortgages (which was set forth in the securitization documents) gave the banks the right to foreclose.
2. A lender or servicer must be the holder of the mortgage when the power of sale is exercised. Back-dated assignments and assignments made after the exercise of the power of sale do not satisfy this requirement. Confirmatory assignments are effective only if they confirm a written assignment that was in existence when the power of sale was exercised.
3. An assignment of a mortgage in blank, that is, an assignment that does not name the assignee, is invalid.
4. A valid mortgage assignment need not be in recordable form and need not be recorded. An assignment of a pool of mortgages made in an unrecorded securitization document may be valid if the document meets the requirements of M.G.L., Chapter 183, Chapter 3 and if it specifically identifies the mortgages being assigned. The Court noted that the best practice is to record allmortgage assignments in the proper order.
5. The Ibanez decision does not address questions of New York law concerning transfers of securitized mortgages to bond trustees, nor does it address the validity of MERS (Mortgage Electronic Registration Systems) or of mortgage securitization in general. The banks lost because they could not produce valid assignments of the mortgages that they had purported to foreclose.
6. The Ibanez decision is based entirely on existing Massachusetts law and applies only to Massachusetts. Courts in other states that use judicial foreclosure or treat mortgages as liens rather than conveyances of legal title to real estate may reach different results on similar facts.
When foreclosing a mortgage in Massachusetts, we have recommended to our clients that ownership of both the note and mortgage be transferred of record to a single asset entity established by the lender for the purpose of foreclosing the mortgage and taking title to the property after the foreclosure sale. We have also recommended that lenders obtain a commitment for a new owner's policy of title insurance, which will insure the validity of the foreclosure sale and the validity of any assignments of the mortgage. The Ibanez decision confirms our belief in the soundness of this advice.
When drafting a mortgage for a loan, which may be securitized or which may become subject to some form of co-lending agreement (such as an A and B note structure), particular attention should be paid to the drafting of the power of sale clause. There should be no ambiguity as to who has the power to foreclose the mortgage if ownership of the note should become separated from legal title to the mortgage or if ownership of the debt should be split among several parties.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances
When the mortgage company issues a 1099 for deficiency
Question:
Once the mortgage company has issued a 1099 to the (former) homeowner, is it too late to discharge the deficiency and avoid the income tax liability on the deficiency? I thought there was an IRS regulation that prevented the mortgage company from burdening homestead homeowners with a 1099 when the homestead was lost to foreclosure. Am I remembering correctly?
Answer:
My understanding is that when the taxable event occurs prior to filing the BK, the debtor is still responsible for the tax liability. However, if the 1099 was filed on a homestead property (as homestead is defined by the IRS, which I believe requires living in the property 2 or 3 out of the past 5 years), the debtor will not have tax liability on the 1099 if the proper paperwork is filed when doing their taxes. See the following IRS article on the Mortgage Forgiveness Debt Relief Act:
http://www.irs.gov/newsroom/article/0,,id=174034,00.html
Home Owners Associations Seizing Property Without Foreclosing
http://www.tampabay.com/news/business/realestate/article1146187.ece
A Florida law enacted on July 1, 2010, allows homeowner and condominium associations to seize rent from tenants who rent from delinquent owners — even before foreclosing.
After obtaining a court order to seize the rent, the associations can collect what is owed, said Tampa lawyer James De Furio, whose practice is devoted to associations.
A Florida law enacted on July 1, 2010, allows homeowner and condominium associations to seize rent from tenants who rent from delinquent owners — even before foreclosing.
After obtaining a court order to seize the rent, the associations can collect what is owed, said Tampa lawyer James De Furio, whose practice is devoted to associations.
Commentary:
The Times article is somewhat misleading. Property is not being “seized” by associations. When the association forecloses and takes title it may rent out the property. In a pending foreclosure the association may ask the court to order rents to be paid to a receiver or into the registry. The new statutes allow for a demand for rents without filing suit and eviction if the rents are not paid. See F.S. §718.116(11) for condos and 720.3085(8) for homeowners.
House Majority Leader: No Bankruptcy or Bailouts for States
U.S. House of Representatives Majority Leader Eric Cantor (R) said yesterday that he does not support any federal bailouts for states or allowing them to declare bankruptcy, Reuters reported yesterday. "I don't think that [bankruptcy] is necessary because state governments have at their disposal the requisite tools to address their fiscal ills," Cantor said. Last week, Newt Gingrich, the conservative Republican and former House Speaker, said that legislation was being prepared in Congress to let states declare bankruptcy -- an idea that the potential 2012 presidential candidate had been talking up. Gingrich's remarks came despite resistance from states and investors in the $2.8 trillion municipal bond market to such a move.
http://www.reuters.com/article/idUSTRE70N5T420110124
In related news, Connecticut Gov. Dannel P. Malloy (D) is ruling out any thought of Connecticut declaring bankruptcy, despite the state's deficit problems, saying that the idea is wrong-minded and would endanger the municipal bond market, the Associated Press reported yesterday. Malloy said that the marketplace for state and local bonds would disappear if states began filing for bankruptcy. Connecticut's deficit for the new fiscal year is predicted to be $3.4 billion to $3.67 billion.
http://www.bloomberg.com/news/print/2011-01-24/conn-gov-calls-state-bankruptcy-idea-crazy-talk-.html
http://www.reuters.com/article/idUSTRE70N5T420110124
In related news, Connecticut Gov. Dannel P. Malloy (D) is ruling out any thought of Connecticut declaring bankruptcy, despite the state's deficit problems, saying that the idea is wrong-minded and would endanger the municipal bond market, the Associated Press reported yesterday. Malloy said that the marketplace for state and local bonds would disappear if states began filing for bankruptcy. Connecticut's deficit for the new fiscal year is predicted to be $3.4 billion to $3.67 billion.
http://www.bloomberg.com/news/print/2011-01-24/conn-gov-calls-state-bankruptcy-idea-crazy-talk-.html
New York - new bankruptcy exemptions
New York just increased homestead exemption to $150,000 for an individual and $300,000 for a couple from $50,000 which was raised in 2005 from $10,000.
Cash exemption was doubled to $5,000; auto exemption went from $2,400 to $4,000; tools of trade was quintupled to $3,000; aggregate personal property exemption was doubled to $10,000.
You can read about the new, New York exemptions here:
New York Bankruptcy Exemptions Suddenly Increased – This Is the Biggest Bankruptcy News in Years!
http://longislandbankruptcyblog.com/york-bankruptcy-exemptions-suddenly-increased-biggest-bankruptcy-news-years/
and here
The New, New York Bankruptcy Exemption Statutes for 2011
http://longislandbankruptcyblog.com/new-york-bankruptcy-exemption-statutes-for-2011/
Cash exemption was doubled to $5,000; auto exemption went from $2,400 to $4,000; tools of trade was quintupled to $3,000; aggregate personal property exemption was doubled to $10,000.
You can read about the new, New York exemptions here:
New York Bankruptcy Exemptions Suddenly Increased – This Is the Biggest Bankruptcy News in Years!
http://longislandbankruptcyblog.com/york-bankruptcy-exemptions-suddenly-increased-biggest-bankruptcy-news-years/
and here
The New, New York Bankruptcy Exemption Statutes for 2011
http://longislandbankruptcyblog.com/new-york-bankruptcy-exemption-statutes-for-2011/
Monday, January 24, 2011
Judges to Weigh Mortgage Document Destruction
Bankruptcy judges in Delaware are due to hold separate hearings today on requests by two defunct subprime mortgage lenders to destroy thousands of boxes or original loan documents, Reuters reported yesterday. The requests, by trustees liquidating Mortgage Lenders Network USA and American Home Mortgage, come despite intense concerns that paperwork critical to foreclosures and securitized investments may be lost. In the Mortgage Lenders case, the U.S. Attorney in Delaware has formally objected to the requested destruction because loss of the records "threatens to impair federal law enforcement efforts."
http://www.reuters.com/article/idUSTRE70M1YJ20110123?feedType=RSS&feedName=topNews
http://www.reuters.com/article/idUSTRE70M1YJ20110123?feedType=RSS&feedName=topNews
Mortgage Giants Leave Legal Bills to the Taxpayers
Since the government took over Fannie Mae and Freddie Mac, taxpayers have spent more than $160 million defending the mortgage finance companies and their former top executives in civil lawsuits accusing them of fraud, the New York Times reported today. The bulk of those expenditures - $132 million - went to defend Fannie Mae and its officials in various securities suits and government investigations into accounting irregularities that occurred years before the subprime lending crisis erupted.
Documents reviewed by The New York Times indicate that taxpayers have paid $24.2 million to law firms defending three of Fannie’s former top executives: Franklin D. Raines, its former chief executive; Timothy Howard, its former chief financial officer; and Leanne Spencer, the former controller. After the government moved to back Fannie and Freddie, the Federal Housing Finance Agency agreed to continue paying to defend the executives, with the taxpayers covering the costs.
http://www.nytimes.com/2011/01/24/business/24fees.html
Since Fannie Mae and Freddie Mac were taken over by the government in September 2008, their losses stemming from bad loans have mounted, totaling about $150 billion in a recent reckoning. Because the financial regulatory overhaul passed last summer did not address how to resolve Fannie and Freddie, Congress is expected to take up that complex matter this year.
Documents reviewed by The New York Times indicate that taxpayers have paid $24.2 million to law firms defending three of Fannie’s former top executives: Franklin D. Raines, its former chief executive; Timothy Howard, its former chief financial officer; and Leanne Spencer, the former controller. After the government moved to back Fannie and Freddie, the Federal Housing Finance Agency agreed to continue paying to defend the executives, with the taxpayers covering the costs.
http://www.nytimes.com/2011/01/24/business/24fees.html
Since Fannie Mae and Freddie Mac were taken over by the government in September 2008, their losses stemming from bad loans have mounted, totaling about $150 billion in a recent reckoning. Because the financial regulatory overhaul passed last summer did not address how to resolve Fannie and Freddie, Congress is expected to take up that complex matter this year.
Mortgage Giants Leave Legal Bills to the Taxpayers
Since the government took over Fannie Mae and Freddie Mac, taxpayers have spent more than $160 million defending the mortgage finance companies and their former top executives in civil lawsuits accusing them of fraud, the New York Times reported today. The bulk of those expenditures - $132 million - went to defend Fannie Mae and its officials in various securities suits and government investigations into accounting irregularities that occurred years before the subprime lending crisis erupted.
Documents reviewed by The New York Times indicate that taxpayers have paid $24.2 million to law firms defending three of Fannie’s former top executives: Franklin D. Raines, its former chief executive; Timothy Howard, its former chief financial officer; and Leanne Spencer, the former controller. After the government moved to back Fannie and Freddie, the Federal Housing Finance Agency agreed to continue paying to defend the executives, with the taxpayers covering the costs.
http://www.nytimes.com/2011/01/24/business/24fees.html
Since Fannie Mae and Freddie Mac were taken over by the government in September 2008, their losses stemming from bad loans have mounted, totaling about $150 billion in a recent reckoning. Because the financial regulatory overhaul passed last summer did not address how to resolve Fannie and Freddie, Congress is expected to take up that complex matter this year.
Documents reviewed by The New York Times indicate that taxpayers have paid $24.2 million to law firms defending three of Fannie’s former top executives: Franklin D. Raines, its former chief executive; Timothy Howard, its former chief financial officer; and Leanne Spencer, the former controller. After the government moved to back Fannie and Freddie, the Federal Housing Finance Agency agreed to continue paying to defend the executives, with the taxpayers covering the costs.
http://www.nytimes.com/2011/01/24/business/24fees.html
Since Fannie Mae and Freddie Mac were taken over by the government in September 2008, their losses stemming from bad loans have mounted, totaling about $150 billion in a recent reckoning. Because the financial regulatory overhaul passed last summer did not address how to resolve Fannie and Freddie, Congress is expected to take up that complex matter this year.
HK bankruptcy petitions up 3.4 pct in Dec vs Nov
HONG KONG, Jan 21 (Reuters) - Hong Kong bankruptcy petitions totalled 704 in December, up 3.4 percent from November but down 22.4 percent compared with the same month last year, government data showed on Friday.
FANNIE MAE OKS FORECLOSURE DELAYS FOR HARDEST HIT FUND ASSISTANCE
http://www.dsnews.com/articles/fannie-mae-oks-foreclosure-delays-for-hardest-hit-fund-assistance-2011-01-21
Fannie Mae has issued a notice to its servicers, instructing them to postpone foreclosure proceedings for unemployed homeowners who are receiving help through Hardest-Hit Fund programs run by state housing finance agencies. According to the GSE's newly released directive, if a housing finance agency (HFA) notifies a servicer that a borrower has been approved for assistance, the servicer must not refer the mortgage loan to foreclosure or conduct a scheduled foreclosure sale for 45 days.
Fannie Mae has issued a notice to its servicers, instructing them to postpone foreclosure proceedings for unemployed homeowners who are receiving help through Hardest-Hit Fund programs run by state housing finance agencies. According to the GSE's newly released directive, if a housing finance agency (HFA) notifies a servicer that a borrower has been approved for assistance, the servicer must not refer the mortgage loan to foreclosure or conduct a scheduled foreclosure sale for 45 days.
States Going Bankrupt??
http://www.reuters.com/article/idUSN2115727620110121
Gingrich: Bankruptcy Bill for States Imminent
Legislation that would allow U.S. states to file for bankruptcy will likely be introduced in Congress within the next month, said Newt Gingrich, the former speaker of the House of Representatives, Reuters reported on Friday. For months Gingrich has championed letting states file for bankruptcy as a way of handling their long-term budget problems despite resistance from states and investors in the $2.8 trillion municipal bond market and questions about the sovereignty of states under the Constitution. While he declined to comment on who might In related news, while Massachusetts is facing at least a $1 billion budget gap, Gov. Deval Patrick said that there is no need for the state to consider filing for bankruptcy, the Associated Press reported on Friday. Patrick will unveil a fiscal 2012 budget next week containing heavy cuts in large part required by a loss of federal stimulus money. California, the eighth largest economy in the world, would not benefit from bankruptcy legislation, Treasurer Bill Lockyer said. "States didn't ask for it. We don't want it. We don't need it," Lockyer said. "Bankruptcy would devastate states' ability to recover from the recession and make the infrastructure investments that create good jobs."introduce legislation, Gingrich said that there was support in both the House and the Senate and that lawmakers have been looking into the idea for three or four months.
http://www.bloomberg.com/news/print/2011-01-21/governor-mass-doesn-t-need-state-bankruptcy.html
http://online.wsj.com/article/SB10001424052748704881304576094091992370356.html#
Gingrich: Bankruptcy Bill for States Imminent
Legislation that would allow U.S. states to file for bankruptcy will likely be introduced in Congress within the next month, said Newt Gingrich, the former speaker of the House of Representatives, Reuters reported on Friday. For months Gingrich has championed letting states file for bankruptcy as a way of handling their long-term budget problems despite resistance from states and investors in the $2.8 trillion municipal bond market and questions about the sovereignty of states under the Constitution. While he declined to comment on who might In related news, while Massachusetts is facing at least a $1 billion budget gap, Gov. Deval Patrick said that there is no need for the state to consider filing for bankruptcy, the Associated Press reported on Friday. Patrick will unveil a fiscal 2012 budget next week containing heavy cuts in large part required by a loss of federal stimulus money. California, the eighth largest economy in the world, would not benefit from bankruptcy legislation, Treasurer Bill Lockyer said. "States didn't ask for it. We don't want it. We don't need it," Lockyer said. "Bankruptcy would devastate states' ability to recover from the recession and make the infrastructure investments that create good jobs."introduce legislation, Gingrich said that there was support in both the House and the Senate and that lawmakers have been looking into the idea for three or four months.
http://www.bloomberg.com/news/print/2011-01-21/governor-mass-doesn-t-need-state-bankruptcy.html
http://online.wsj.com/article/SB10001424052748704881304576094091992370356.html#
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