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Tuesday, January 18, 2011
Making Money Work
I recently watched the movie Exit Through the Gift Shop from well-known artist Banksy. I got a kick out of this film for multiple reasons having liked Banksy's artwork for years now.
What most amused me though is how well it goes about making you question what celebrity is and how much you can achieve by becoming famous. The key point for me is questioning whether you really need to be creative and innovative above and beyond being famous.
Then Mike Butcher over at Techcrunch went and posted something this morning about startup teams trumping celebrity tech entrepreneurs. In summary, he too is making the point that execution far outweighs celebrity.
Basically, what I'm getting at, is all the parallels you're starting to see between the startup world and the movie business. I am definitely not an expert on the movie business and can only imagine what it's truly like from afar. Yet, we've all seen enough of it to realize a bit how things work in Hollywood. You basically have a couple large companies or studios as they're usually called. There you have management at the top who are the power-brokers in the industry. They back films which are used as vehicles to market actors who either succeed or not. If they do succeed, they are cast in further films and a ton of marketing is thrown at these films, regardless of whether these actors have talent or not.
Ultimately, the goal is to make as much money as possible and if you're the one making all this money, keep other people out so you can continue to make as much money as possible. Sure, there are some stand-out actors, managers and studios who go against the grain but basically it's an industry optimized to make money. Simplified by me immensely but I believe you understand what I am saying.
Now let's switch over to the startup world. It's no longer Hollywood and we're now a bit north in Silicon Valley. You have a couple firms who call all the shots and are known as Tier 1 VC's (with some major players like Google, Apple, and Facebook thrown in for good measure).
These VC's fund firms instead of films run by entrepreneurs instead of actors. Some of these entrepreneurs are successful and some are not. Those who are get funded further by these Tier 1 firms. Lots of companies are started and sold since these power brokers in the Valley sit on each other's boards and pass deals back and forth. The power brokers continue to make money and those entrepreneurs who don't lead to successful exits get weeded out (where's the reality TV version of "out to pasture" for entrepreneurs?)
Ultimately, as in the movie business, you make as much money as possible and keep out the riff-raff who would keep you from making tons of money as long as possible.
Now don't get me wrong. I am in no way arguing about whether the movie or startup business is right or wrong or skewed in someone's favor or not. I'm also probably simplifying it too much as well. But the point I am making is that we are in a world where it's about making money. Sure, you can get your touchy-feely on and say you're changing the world but ultimately you wouldn't "work" if it wasn't about making some money.
Hence, my advice to any entrepreneur is to take advantage of whatever you have if you ultimately want to be successful. If you are naturally good looking, get your face out there. Be on TV and in the press. If it helps you make money, go for it.
At the same time, if media attention doesn't help you make more money, don't focus on it. Get your pretty head down to business and execute like hell to innovate, optimize and sell your product. Or have the best of both worlds. Be a CEO focussed on getting your brand or product out there and have a number two (great blog post by Ben Horowitz) who takes care of business. What you need to focus on is making money and being the scrappy entrepreneur that you are, you'll optimize wherever you can to achieve your goal.
In the end it's never about who was most popular that determines success. Just think back to all those football players and cheerleaders in high school. (I've seen some of them from my high school....thank you Facebook.....and had a good laugh!) So often there are people you never hear about making tons of cash since they don't need to focus on media.
On the other hand, if Twitter/Foursquare/Zynga/Groupon hadn't received so much media attention, you think they'd be where they are now? I highly doubt it and I guarantee you that they had a clear strategy in place to use media (and position their founders) from the start. Hence, don't waste time focussed on the wrong things. If you're a celebrity entrepreneur who's counting his millions hats off to you. If you've become a media darling and are broke, well tough luck kid. Try something new.
By the way, here's what Exit Through the Gift Shop is about cut and pasted from Wikipedia. Think what you will about whether it's a real story or not but reast assured the dollars earned by "Mr Brainwash" were real!!
Exit Through the Gift Shop: A Banksy Film is a Gonzo Documentary which tells the story of Thierry Guetta, a French immigrant in Los Angeles, and his obsession with street art. It is presented as a documentary, but reviewers have questioned its factuality. The film charts Guetta's constant documenting of his every moment on film, to his chance contact with his cousin, the artist Invader, and his documenting of a host of street artists with focus on Shepard Fairey, and also Banksy though the latter's face is never shown, and his voice is distorted to preserve his anonymity
By Lindsay Beyerstein, Media Consortium blogger
Meet the new global elite. They're pretty much the same as the old global elite, only richer and more smug.
Laura Flanders of GritTV interviews business reporter Chrystia Freeland about her cover story in the latest issue of the Atlantic Monthly on the new ruling class. She says that today's ultra-rich are more likely to have earned their fortunes in Silicon Valley or on Wall Street than previous generations of plutocrats, who were more likely to have inherited money or established companies.
As a result, she argues, today's global aristocracy believes itself to be the product of a meritocracy. The old sense of noblesse oblige among the ultra-rich is giving way to the attitude that if the ultra-rich could do it, everyone else should pull themselves up by their bootstraps.
Ironically, Freeland points out that many of the new elite got rich from government bailouts of their failed banks. It's unclear why this counts as earning one's fortune, or what kind of meritocracy reserves its most lavish rewards for its most spectacular failures.
Class warfare on public sector pensions
In The Nation, Eric Alterman assails the Republican-controlled Congress's decision to scrap the popular and effective Build America Bonds program as an act of little-noticed class warfare:
These bonds, which make up roughly 20 percent of all new debt sold by states and local governments because of a federal subsidy equivalent to some 35 percent of interest costs, ended on December 31, as Republicans proved unwilling even to consider renewing them. The death of the program could prove devastating to states' future borrowing.
Alterman notes that the states could face up to $130 billion shortfall next year. States can't deficit spend like the federal government, which made the Build America Bonds program a lifeline to the states.
According to Alterman, Republicans want the states to run out of money so that they will be unable to pay the pensions of public sector workers. He notes that Reps. Devin Nunes (R-CA), Darrell Issa (R-CA) and Paul Ryan (R-WI) are also co-sponsoring a bill to force state and local governments to "recalculate" their pension obligations to public sector workers.
Divide and conquer
Kari Lydersen of Working In These Times explains how conservatives use misleading statistics to pit private sector workers against their brothers and sisters in the public sector. If the public believes that teachers, firefighters, meter readers and snowplow drivers are parasites, they'll feel more comfortable yanking their pensions out from under them.
Hence the misleading statistic that public sector workers earn $11.90 more per hour than "comparable" private sector workers. However, when you take education and work experience into account, employees of state and local governments typically earn 11% to 12% less than private sector workers with comparable qualifications.
Public sector workers have better benefits plans, but only for as long as governments can afford to keep their contractual obligations.
Who's screwing whom?
Former Secretary of Labor Robert Reich is calling for a sense of perspective on public sector wages and benefits. In AlterNet he argues that the people who are really making a killing in this economy are the ultra-rich, not school teachers and garbage collectors:
Public servants are convenient scapegoats. Republicans would rather deflect attention from corporate executive pay that continues to rise as corporate profits soar, even as corporations refuse to hire more workers. They don't want stories about Wall Street bonuses, now higher than before taxpayers bailed out the Street. And they'd like to avoid a spotlight on the billions raked in by hedge-fund and private-equity managers whose income is treated as capital gains and subject to only a 15 percent tax, due to a loophole in the tax laws designed specifically for them.
Signs of hope?
The economic future looks pretty bleak these days. Yes, the unemployment rate dropped to 9.4% from 9.8% in December, but the economy added only 103,000, a far cry from the 300,000 jobs economists say the economy really needs to add to pull the country out its economic doldrums.
Andy Kroll points out in Mother Jones that it will take 20 years to replace the jobs lost in this recession, if current trends continue.
Worse yet, what looks like job growth could actually be chronic unemployment in disguise. The unemployment rate is calculated based on the number of people who are actively looking for work. Kroll worries that the apparent drop in the unemployment rate could simply reflect more people giving up their job searches.
For an counterweight to the doom and gloom, check out Tim Fernholtz's new piece in The American Prospect. He argues that the new unemployment numbers are among several hopeful signs for economic recovery in 2011. However, he stresses that his self-proclaimed rosy forecast is contingent upon avoiding several huge pitfalls, including drastic cuts in public spending.
With the GOP in Congress seemingly determined to starve the states for cash, the future might not be so rosy after all.
This post features links to the best independent, progressive reporting about the economy by members of The Media Consortium. It is free to reprint. Visit the Audit for a complete list of articles on economic issues, or follow us on Twitter. And for the best progressive reporting on critical economy, environment, health care and immigration issues, check out The Mulch, The Pulse and The Diaspora. This is a project of The Media Consortium, a network of leading independent media outlets.
Source:http://removeripoffreports.net/
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elect Robert Bentley intends to be governor over all, but says only Christians are his 'brothers and sisters'. Published: Monday, January 17, 2011, 4:23 PM Updated: Monday, January 17, 2011, 6:14 PM. David White -- The Birmingham News ...
Live blog: Apple's Q1 2011 financials conference call | iLounge <b>News</b>
iLounge news discussing the Live blog: Apple's Q1 2011 financials conference call. Find more Apple news from leading independent iPod, iPhone, and iPad site.
Pitchfork: The Strokes Confirm Release Date for New Record
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Friday, January 14, 2011
personal finance budgets
Intuit-owned Mint.com is heading to schools today with the launch of a free, online program designed to educate middle-school students about personal finance and financial management.
Mint has partnered with educational publisher Scholastic to develop materials that parents and teachers can use to teach children the ins and outs of personal finance management. The materials includes lesson plans as well as an interactive game, to teach children money management, budgeting and goals.
For example, the program teaches children the concept of compound interest with real-life math problems, and encourages children to set goals and budgets with their own current work opportunities (i.e. babysitting).
Mint says the curriculum will be expanded to 30,000 classrooms nationwide early next year. Considering the state of the economy and credit, teaching children financial literacy and sounds personal finance practices at an early edge is an incredibly important initiative. In terms of branding, this is a big win for Mint, which can start building awareness of its tools among students at an early age.
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Blagojevich defense wants Obama subpoenaed - Chicago Breaking <b>News</b>
Attorneys for former Gov. Rod Blagojevich today asked a federal judge to subpoena President Barack Obama to testify in Blagojevich's upcoming corruption trial on charges that include allegations Blagojevich sought to sell Obama's former ...
The Write Stuff For Test Anxiety - Science <b>News</b>
Students score higher after jotting down worries before a big exam.
BillBoard - Blogs - The Buffalo <b>News</b>
The Buffalo News updated every day with news from Buffalo, New York. Links to national and business news, entertainment listings, recipes, sports teams, classified ads, death notices.
Thursday, January 13, 2011
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A bomb specialist enters Fitzsimons Park near Nichols Middle School in Evanston on Tuesday. (José M. Osorio/ Chicago Tribune) In the dead of night, an explosion ripped through Evanston's Fitzsimmons Park, shaking houses and waking ...
Blagojevich defense wants Obama subpoenaed - Chicago Breaking <b>News</b>
Attorneys for former Gov. Rod Blagojevich today asked a federal judge to subpoena President Barack Obama to testify in Blagojevich's upcoming corruption trial on charges that include allegations Blagojevich sought to sell Obama's former ...
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A Roman Catholic parish in West Chicago that has been beset with bad news in recent months received more on Wednesday. The former deacon and bookkeeper at St. Mary's Parish was charged with stealing more than $315000 from the parish to ...
Monday, January 10, 2011
foreclosure law
Massachusetts Supreme Court—Opinion against banks in land title records —-u s Bank v Ibanez Sjc Slip O…
Text After the jump
Published: 11:40 am Fri, January 7, 2011 11:40 am Fri, January 7, 2011
By Tom Egan Massachusetts Lawyers Weekly
NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA 02108-1750; (617) 557-1030; SJCReporter@sjc.state.ma.us
SJC-10694
U.S. BANK NATIONAL ASSOCIATION, trustee1 vs. ANTONIO IBANEZ (and a consolidated case2,3).
Suffolk. October 7, 2010. – January 7, 2011.
Present: Marshall, C.J., Ireland, Spina, Cordy, Botsford, & Gants, JJ.4
Real Property, Mortgage, Ownership, Record title. Mortgage, Real estate, Foreclosure, Assignment. Notice, Foreclosure of mortgage.
Civil actions commenced in the Land Court Department on September 16 and October 30, 2008.
Motions for entry of default judgment and to vacate judgment were heard by Keith C. Long, J.
The Supreme Judicial Court granted an application for direct appellate review.
R. Bruce Allensworth (Phoebe S. Winder & Robert W. Sparkes, III, with him) for U.S. Bank National Association & another.
Paul R. Collier, III (Max W. Weinstein with him) for Antonio Ibanez.
Glenn F. Russell, Jr., for Mark A. LaRace & another.
The following submitted briefs for amici curiae:
Martha Coakley, Attorney General, & John M. Stephan, Assistant Attorney General, for the Commonwealth.
Kevin Costello, Gary Klein, Shennan Kavanagh & Stuart Rossman for National Consumer Law Center & others.
Ward P. Graham & Robert J. Moriarty, Jr., for Real Estate Bar Association for Massachusetts, Inc.
Marie McDonnell, pro se.
GANTS, J. After foreclosing on two properties and purchasing the properties back at the foreclosure sales, U.S. Bank National Association (U.S. Bank), as trustee for the Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2006-Z; and Wells Fargo Bank, N.A. (Wells Fargo), as trustee for ABFC 2005-OPT 1 Trust, ABFC Asset Backed Certificates, Series 2005-OPT 1 (plaintiffs) filed separate complaints in the Land Court asking a judge to declare that they held clear title to the properties in fee simple. We agree with the judge that the plaintiffs, who were not the original mortgagees, failed to make the required showing that they were the holders of the mortgages at the time of foreclosure. As a result, they did not demonstrate that the foreclosure sales were valid to convey title to the subject properties, and their requests for a declaration of clear title were properly denied.5
Procedural history. On July 5, 2007, U.S. Bank, as trustee, foreclosed on the mortgage of Antonio Ibanez, and purchased the Ibanez property at the foreclosure sale. On the same day, Wells Fargo, as trustee, foreclosed on the mortgage of Mark and Tammy LaRace, and purchased the LaRace property at that foreclosure sale.
In September and October of 2008, U.S. Bank and Wells Fargo brought separate actions in the Land Court under G. L. c. 240, § 6, which authorizes actions “to quiet or establish the title to land situated in the commonwealth or to remove a cloud from the title thereto.” The two complaints sought identical relief: (1) a judgment that the right, title, and interest of the mortgagor (Ibanez or the LaRaces) in the property was extinguished by the foreclosure; (2) a declaration that there was no cloud on title arising from publication of the notice of sale in the Boston Globe; and (3) a declaration that title was vested in the plaintiff trustee in fee simple. U.S. Bank and Wells Fargo each asserted in its complaint that it had become the holder of the respective mortgage through an assignment made after the foreclosure sale.
In both cases, the mortgagors — Ibanez and the LaRaces — did not initially answer the complaints, and the plaintiffs moved for entry of default judgment. In their motions for entry of default judgment, the plaintiffs addressed two issues: (1) whether the Boston Globe, in which the required notices of the foreclosure sales were published, is a newspaper of “general circulation” in Springfield, the town where the foreclosed properties lay. See G. L. c. 244, § 14 (requiring publication every week for three weeks in newspaper published in town where foreclosed property lies, or of general circulation in that town); and (2) whether the plaintiffs were legally entitled to foreclose on the properties where the assignments of the mortgages to the plaintiffs were neither executed nor recorded in the registry of deeds until after the foreclosure sales.6 The two cases were heard together by the Land Court, along with a third case that raised the same issues.
On March 26, 2009, judgment was entered against the plaintiffs. The judge ruled that the foreclosure sales were invalid because, in violation of G. L. c. 244, § 14, the notices of the foreclosure sales named U.S. Bank (in the Ibanez foreclosure) and Wells Fargo (in the LaRace foreclosure) as the mortgage holders where they had not yet been assigned the mortgages.7 The judge found, based on each plaintiff’s assertions in its complaint, that the plaintiffs acquired the mortgages by assignment only after the foreclosure sales and thus had no interest in the mortgages being foreclosed at the time of the publication of the notices of sale or at the time of the foreclosure sales.8
The plaintiffs then moved to vacate the judgments. At a hearing on the motions on April 17, 2009, the plaintiffs conceded that each complaint alleged a postnotice, postforeclosure sale assignment of the mortgage at issue, but they now represented to the judge that documents might exist that could show a prenotice, preforeclosure sale assignment of the mortgages. The judge granted the plaintiffs leave to produce such documents, provided they were produced in the form they existed in at the time the foreclosure sale was noticed and conducted. In response, the plaintiffs submitted hundreds of pages of documents to the judge, which they claimed established that the mortgages had been assigned to them before the foreclosures. Many of these documents related to the creation of the securitized mortgage pools in which the Ibanez and LaRace mortgages were purportedly included.9
The judge denied the plaintiffs’ motions to vacate judgment on October 14, 2009, concluding that the newly submitted documents did not alter the conclusion that the plaintiffs were not the holders of the respective mortgages at the time of foreclosure. We granted the parties’ applications for direct appellate review.
Factual background. We discuss each mortgage separately, describing when appropriate what the plaintiffs allege to have happened and what the documents in the record demonstrate.10
The Ibanez mortgage. On December 1, 2005, Antonio Ibanez took out a $103,500 loan for the purchase of property at 20 Crosby Street in Springfield, secured by a mortgage to the lender, Rose Mortgage, Inc. (Rose Mortgage). The mortgage was recorded the following day. Several days later, Rose Mortgage executed an assignment of this mortgage in blank, that is, an assignment that did not specify the name of the assignee.11 The blank space in the assignment was at some point stamped with the name of Option One Mortgage Corporation (Option One) as the assignee, and that assignment was recorded on June 7, 2006. Before the recording, on January 23, 2006, Option One executed an assignment of the Ibanez mortgage in blank.
According to U.S. Bank, Option One assigned the Ibanez mortgage to Lehman Brothers Bank, FSB, which assigned it to Lehman Brothers Holdings Inc., which then assigned it to the Structured Asset Securities Corporation,12 which then assigned the mortgage, pooled with approximately 1,220 other mortgage loans, to U.S. Bank, as trustee for the Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2006-Z. With this last assignment, the Ibanez and other loans were pooled into a trust and converted into mortgage-backed securities that can be bought and sold by investors — a process known as securitization.
For ease of reference, the chain of entities through which the Ibanez mortgage allegedly passed before the foreclosure sale is:
Rose Mortgage, Inc. (originator)
Option One Mortgage Corporation (record holder)
Lehman Brothers Bank, FSB
Lehman Brothers Holdings Inc. (seller)
Structured Asset Securities Corporation (depositor)
U.S. Bank National Association, as trustee for the Structured Asset Securities Corporation Mortgage Pass-Through Certificates, Series 2006-Z
According to U.S. Bank, the assignment of the Ibanez mortgage to U.S. Bank occurred pursuant to a December 1, 2006, trust agreement, which is not in the record. What is in the record is the private placement memorandum (PPM), dated December 26, 2006, a 273-page, unsigned offer of mortgage-backed securities to potential investors. The PPM describes the mortgage pools and the entities involved, and summarizes the provisions of the trust agreement, including the representation that mortgages “will be” assigned into the trust. According to the PPM, “[e]ach transfer of a Mortgage Loan from the Seller [Lehman Brothers Holdings Inc.] to the Depositor [Structured Asset Securities Corporation] and from the Depositor to the Trustee [U.S. Bank] will be intended to be a sale of that Mortgage Loan and will be reflected as such in the Sale and Assignment Agreement and the Trust Agreement, respectively.” The PPM also specifies that “[e]ach Mortgage Loan will be identified in a schedule appearing as an exhibit to the Trust Agreement.” However, U.S. Bank did not provide the judge with any mortgage schedule identifying the Ibanez loan as among the mortgages that were assigned in the trust agreement.
On April 17, 2007, U.S. Bank filed a complaint to foreclose on the Ibanez mortgage in the Land Court under the Servicemembers Civil Relief Act (Servicemembers Act), which restricts foreclosures against active duty members of the uniformed services. See 50 U.S.C. Appendix §§ 501, 511, 533 (2006 & Supp. II 2008).13 In the complaint, U.S. Bank represented that it was the “owner (or assignee) and holder” of the mortgage given by Ibanez for the property. A judgment issued on behalf of U.S. Bank on June 26, 2007, declaring that the mortgagor was not entitled to protection from foreclosure under the Servicemembers Act. In June, 2007, U.S. Bank also caused to be published in the Boston Globe the notice of the foreclosure sale required by G. L. c. 244, § 14. The notice identified U.S. Bank as the “present holder” of the mortgage.
At the foreclosure sale on July 5, 2007, the Ibanez property was purchased by U.S. Bank, as trustee for the securitization trust, for $94,350, a value significantly less than the outstanding debt and the estimated market value of the property. The foreclosure deed (from U.S. Bank, trustee, as the purported holder of the mortgage, to U.S. Bank, trustee, as the purchaser) and the statutory foreclosure affidavit were recorded on May 23, 2008. On September 2, 2008, more than one year after the sale, and more than five months after recording of the sale, American Home Mortgage Servicing, Inc., “as successor-in-interest” to Option One, which was until then the record holder of the Ibanez mortgage, executed a written assignment of that mortgage to U.S. Bank, as trustee for the securitization trust.14 This assignment was recorded on September 11, 2008.
The LaRace mortgage. On May 19, 2005, Mark and Tammy LaRace gave a mortgage for the property at 6 Brookburn Street in Springfield to Option One as security for a $103,200 loan; the mortgage was recorded that same day. On May 26, 2005, Option One executed an assignment of this mortgage in blank.
According to Wells Fargo, Option One later assigned the LaRace mortgage to Bank of America in a July 28, 2005, flow sale and servicing agreement. Bank of America then assigned it to Asset Backed Funding Corporation (ABFC) in an October 1, 2005, mortgage loan purchase agreement. Finally, ABFC pooled the mortgage with others and assigned it to Wells Fargo, as trustee for the ABFC 2005-OPT 1 Trust, ABFC Asset-Backed Certificates, Series 2005-OPT 1, pursuant to a pooling and servicing agreement (PSA).
For ease of reference, the chain of entities through which the LaRace mortgage allegedly passed before the foreclosure sale is:
Option One Mortgage Corporation (originator and record holder)
Bank of America
Asset Backed Funding Corporation (depositor)
Wells Fargo, as trustee for the ABFC 2005-OPT 1, ABFC Asset-Backed Certificates, Series 2005-OPT 1
Wells Fargo did not provide the judge with a copy of the flow sale and servicing agreement, so there is no document in the record reflecting an assignment of the LaRace mortgage by Option One to Bank of America. The plaintiff did produce an unexecuted copy of the mortgage loan purchase agreement, which was an exhibit to the PSA. The mortgage loan purchase agreement provides that Bank of America, as seller, “does hereby agree to and does hereby sell, assign, set over, and otherwise convey to the Purchaser [ABFC], without recourse, on the Closing Date . . . all of its right, title and interest in and to each Mortgage Loan.” The agreement makes reference to a schedule listing the assigned mortgage loans, but this schedule is not in the record, so there was no document before the judge showing that the LaRace mortgage was among the mortgage loans assigned to the ABFC.
Wells Fargo did provide the judge with a copy of the PSA, which is an agreement between the ABFC (as depositor), Option One (as servicer), and Wells Fargo (as trustee), but this copy was downloaded from the Securities and Exchange Commission website and was not signed. The PSA provides that the depositor “does hereby transfer, assign, set over and otherwise convey to the Trustee, on behalf of the Trust . . . all the right, title and interest of the Depositor . . . in and to . . . each Mortgage Loan identified on the Mortgage Loan Schedules,” and “does hereby deliver” to the trustee the original mortgage note, an original mortgage assignment “in form and substance acceptable for recording,” and other documents pertaining to each mortgage.
The copy of the PSA provided to the judge did not contain the loan schedules referenced in the agreement. Instead, Wells Fargo submitted a schedule that it represented identified the loans assigned in the PSA, which did not include property addresses, names of mortgagors, or any number that corresponds to the loan number or servicing number on the LaRace mortgage. Wells Fargo contends that a loan with the LaRace property’s zip code and city is the LaRace mortgage loan because the payment history and loan amount matches the LaRace loan.
On April 27, 2007, Wells Fargo filed a complaint under the Servicemembers Act in the Land Court to foreclose on the LaRace mortgage. The complaint represented Wells Fargo as the “owner (or assignee) and holder” of the mortgage given by the LaRaces for the property. A judgment issued on behalf of Wells Fargo on July 3, 2007, indicating that the LaRaces were not beneficiaries of the Servicemembers Act and that foreclosure could proceed in accordance with the terms of the power of sale. In June, 2007, Wells Fargo caused to be published in the Boston Globe the statutory notice of sale, identifying itself as the “present holder” of the mortgage.
At the foreclosure sale on July 5, 2007, Wells Fargo, as trustee, purchased the LaRace property for $120,397.03, a value significantly below its estimated market value. Wells Fargo did not execute a statutory foreclosure affidavit or foreclosure deed until May 7, 2008. That same day, Option One, which was still the record holder of the LaRace mortgage, executed an assignment of the mortgage to Wells Fargo as trustee; the assignment was recorded on May 12, 2008. Although executed ten months after the foreclosure sale, the assignment declared an effective date of April 18, 2007, a date that preceded the publication of the notice of sale and the foreclosure sale.
Discussion. The plaintiffs brought actions under G. L. c. 240, § 6, seeking declarations that the defendant mortgagors’ titles had been extinguished and that the plaintiffs were the fee simple owners of the foreclosed properties. As such, the plaintiffs bore the burden of establishing their entitlement to the relief sought. Sheriff’s Meadow Found., Inc. v. Bay-Courte Edgartown, Inc., 401 Mass. 267, 269 (1987). To meet this burden, they were required “not merely to demonstrate better title . . . than the defendants possess, but . . . to prove sufficient title to succeed in [the] action.” Id. See NationsBanc Mtge. Corp. v. Eisenhauer, 49 Mass. App. Ct. 727, 730 (2000). There is no question that the relief the plaintiffs sought required them to establish the validity of the foreclosure sales on which their claim to clear title rested.
Massachusetts does not require a mortgage holder to obtain judicial authorization to foreclose on a mortgaged property. See G. L. c. 183, § 21; G. L. c. 244, § 14. With the exception of the limited judicial procedure aimed at certifying that the mortgagor is not a beneficiary of the Servicemembers Act, a mortgage holder can foreclose on a property, as the plaintiffs did here, by exercise of the statutory power of sale, if such a power is granted by the mortgage itself. See Beaton v. Land Court, 367 Mass. 385, 390-391, 393, appeal dismissed, 423 U.S. 806 (1975).
Where a mortgage grants a mortgage holder the power of sale, as did both the Ibanez and LaRace mortgages, it includes by reference the power of sale set out in G. L. c. 183, § 21, and further regulated by G. L. c. 244, §§ 11-17C. Under G. L. c. 183, § 21, after a mortgagor defaults in the performance of the underlying note, the mortgage holder may sell the property at a public auction and convey the property to the purchaser in fee simple, “and such sale shall forever bar the mortgagor and all persons claiming under him from all right and interest in the mortgaged premises, whether at law or in equity.” Even where there is a dispute as to whether the mortgagor was in default or whether the party claiming to be the mortgage holder is the true mortgage holder, the foreclosure goes forward unless the mortgagor files an action and obtains a court order enjoining the foreclosure.15 See Beaton v. Land Court, supra at 393.
Recognizing the substantial power that the statutory scheme affords to a mortgage holder to foreclose without immediate judicial oversight, we adhere to the familiar rule that “one who sells under a power [of sale] must follow strictly its terms. If he fails to do so there is no valid execution of the power, and the sale is wholly void.” Moore v. Dick, 187 Mass. 207, 211 (1905). See Roche v. Farnsworth, 106 Mass. 509, 513 (1871) (power of sale contained in mortgage “must be executed in strict compliance with its terms”). See also McGreevey v. Charlestown Five Cents Sav. Bank, 294 Mass. 480, 484 (1936).16
One of the terms of the power of sale that must be strictly adhered to is the restriction on who is entitled to foreclose. The “statutory power of sale” can be exercised by “the mortgagee or his executors, administrators, successors or assigns.” G. L. c. 183, § 21. Under G. L. c. 244, § 14, “[t]he mortgagee or person having his estate in the land mortgaged, or a person authorized by the power of sale, or the attorney duly authorized by a writing under seal, or the legal guardian or conservator of such mortgagee or person acting in the name of such mortgagee or person” is empowered to exercise the statutory power of sale. Any effort to foreclose by a party lacking “jurisdiction and authority” to carry out a foreclosure under these statutes is void. Chace v. Morse, 189 Mass. 559, 561 (1905), citing Moore v. Dick, supra. See Davenport v. HSBC Bank USA, 275 Mich. App. 344, 347-348 (2007) (attempt to foreclose by party that had not yet been assigned mortgage results in “structural defect that goes to the very heart of defendant’s ability to foreclose by advertisement,” and renders foreclosure sale void).
A related statutory requirement that must be strictly adhered to in a foreclosure by power of sale is the notice requirement articulated in G. L. c. 244, § 14. That statute provides that “no sale under such power shall be effectual to foreclose a mortgage, unless, previous to such sale,” advance notice of the foreclosure sale has been provided to the mortgagee, to other interested parties, and by publication in a newspaper published in the town where the mortgaged land lies or of general circulation in that town. Id. “The manner in which the notice of the proposed sale shall be given is one of the important terms of the power, and a strict compliance with it is essential to the valid exercise of the power.” Moore v. Dick, supra at 212. See Chace v. Morse, supra (“where a certain notice is prescribed, a sale without any notice, or upon a notice lacking the essential requirements of the written power, would be void as a proceeding for foreclosure”). See also McGreevey v. Charlestown Five Cents Sav. Bank, supra. Because only a present holder of the mortgage is authorized to foreclose on the mortgaged property, and because the mortgagor is entitled to know who is foreclosing and selling the property, the failure to identify the holder of the mortgage in the notice of sale may render the notice defective and the foreclosure sale void.17 See Roche v. Farnsworth, supra (mortgage sale void where notice of sale identified original mortgagee but not mortgage holder at time of notice and sale). See also Bottomly v. Kabachnick, 13 Mass. App. Ct. 480, 483-484 (1982) (foreclosure void where holder of mortgage not identified in notice of sale).
For the plaintiffs to obtain the judicial declaration of clear title that they seek, they had to prove their authority to foreclose under the power of sale and show their compliance with the requirements on which this authority rests. Here, the plaintiffs were not the original mortgagees to whom the power of sale was granted; rather, they claimed the authority to foreclose as the eventual assignees of the original mortgagees. Under the plain language of G. L. c. 183, § 21, and G. L. c. 244, § 14, the plaintiffs had the authority to exercise the power of sale contained in the Ibanez and LaRace mortgages only if they were the assignees of the mortgages at the time of the notice of sale and the subsequent foreclosure sale. See In re Schwartz, 366 B.R. 265, 269 (Bankr. D. Mass. 2007) (“Acquiring the mortgage after the entry and foreclosure sale does not satisfy the Massachusetts statute”).18 See also Jeff-Ray Corp. v. Jacobson, 566 So. 2d 885, 886 (Fla. Dist. Ct. App. 1990) (per curiam) (foreclosure action could not be based on assignment of mortgage dated four months after commencement of foreclosure proceeding).
The plaintiffs claim that the securitization documents they submitted establish valid assignments that made them the holders of the Ibanez and LaRace mortgages before the notice of sale and the foreclosure sale. We turn, then, to the documentation submitted by the plaintiffs to determine whether it met the requirements of a valid assignment.
Like a sale of land itself, the assignment of a mortgage is a conveyance of an interest in land that requires a writing signed by the grantor. See G. L. c. 183, § 3; Saint Patrick’s Religious, Educ. & Charitable Ass’n v. Hale, 227 Mass. 175, 177 (1917). In a “title theory state” like Massachusetts, a mortgage is a transfer of legal title in a property to secure a debt. See Faneuil Investors Group, Ltd. Partnership v. Selectmen of Dennis, 458 Mass. 1, 6 (2010). Therefore, when a person borrows money to purchase a home and gives the lender a mortgage, the homeowner-mortgagor retains only equitable title in the home; the legal title is held by the mortgagee. See Vee Jay Realty Trust Co. v. DiCroce, 360 Mass. 751, 753 (1972), quoting Dolliver v. St. Joseph Fire & Marine Ins. Co., 128 Mass. 315, 316 (1880) (although “as to all the world except the mortgagee, a mortgagor is the owner of the mortgaged lands,” mortgagee has legal title to property); Maglione v. BancBoston Mtge. Corp., 29 Mass. App. Ct. 88, 90 (1990). Where, as here, mortgage loans are pooled together in a trust and converted into mortgage-backed securities, the underlying promissory notes serve as financial instruments generating a potential income stream for investors, but the mortgages securing these notes are still legal title to someone’s home or farm and must be treated as such.
Focusing first on the Ibanez mortgage, U.S. Bank argues that it was assigned the mortgage under the trust agreement described in the PPM, but it did not submit a copy of this trust agreement to the judge. The PPM, however, described the trust agreement as an agreement to be executed in the future, so it only furnished evidence of an intent to assign mortgages to U.S. Bank, not proof of their actual assignment. Even if there were an executed trust agreement with language of present assignment, U.S. Bank did not produce the schedule of loans and mortgages that was an exhibit to that agreement, so it failed to show that the Ibanez mortgage was among the mortgages to be assigned by that agreement. Finally, even if there were an executed trust agreement with the required schedule, U.S. Bank failed to furnish any evidence that the entity assigning the mortgage — Structured Asset Securities Corporation — ever held the mortgage to be assigned. The last assignment of the mortgage on record was from Rose Mortgage to Option One; nothing was submitted to the judge indicating that Option One ever assigned the mortgage to anyone before the foreclosure sale.19 Thus, based on the documents submitted to the judge, Option One, not U.S. Bank, was the mortgage holder at the time of the foreclosure, and U.S. Bank did not have the authority to foreclose the mortgage.
Turning to the LaRace mortgage, Wells Fargo claims that, before it issued the foreclosure notice, it was assigned the LaRace mortgage under the PSA. The PSA, in contrast with U.S. Bank’s PPM, uses the language of a present assignment (“does hereby . . . assign” and “does hereby deliver”) rather than an intent to assign in the future. But the mortgage loan schedule Wells Fargo submitted failed to identify with adequate specificity the LaRace mortgage as one of the mortgages assigned in the PSA. Moreover, Wells Fargo provided the judge with no document that reflected that the ABFC (depositor) held the LaRace mortgage that it was purportedly assigning in the PSA. As with the Ibanez loan, the record holder of the LaRace loan was Option One, and nothing was submitted to the judge which demonstrated that the LaRace loan was ever assigned by Option One to another entity before the publication of the notice and the sale.
Where a plaintiff files a complaint asking for a declaration of clear title after a mortgage foreclosure, a judge is entitled to ask for proof that the foreclosing entity was the mortgage holder at the time of the notice of sale and foreclosure, or was one of the parties authorized to foreclose under G. L. c. 183, § 21, and G. L. c. 244, § 14. A plaintiff that cannot make this modest showing cannot justly proclaim that it was unfairly denied a declaration of clear title. See In re Schwartz, supra at 266 (“When HomEq [Servicing Corporation] was required to prove its authority to conduct the sale, and despite having been given ample opportunity to do so, what it produced instead was a jumble of documents and conclusory statements, some of which are not supported by the documents and indeed even contradicted by them”). See also Bayview Loan Servicing, LLC v. Nelson, 382 Ill. App. 3d 1184, 1188 (2008) (reversing grant of summary judgment in favor of financial entity in foreclosure action, where there was “no evidence that [the entity] ever obtained any legal interest in the subject property”).
We do not suggest that an assignment must be in recordable form at the time of the notice of sale or the subsequent foreclosure sale, although recording is likely the better practice. Where a pool of mortgages is assigned to a securitized trust, the executed agreement that assigns the pool of mortgages, with a schedule of the pooled mortgage loans that clearly and specifically identifies the mortgage at issue as among those assigned, may suffice to establish the trustee as the mortgage holder. However, there must be proof that the assignment was made by a party that itself held the mortgage. See In re Samuels, 415 B.R. 8, 20 (Bankr. D. Mass. 2009). A foreclosing entity may provide a complete chain of assignments linking it to the record holder of the mortgage, or a single assignment from the record holder of the mortgage. See In re Parrish, 326 B.R. 708, 720 (Bankr. N.D. Ohio 2005) (“If the claimant acquired the note and mortgage from the original lender or from another party who acquired it from the original lender, the claimant can meet its burden through evidence that traces the loan from the original lender to the claimant”). The key in either case is that the foreclosing entity must hold the mortgage at the time of the notice and sale in order accurately to identify itself as the present holder in the notice and in order to have the authority to foreclose under the power of sale (or the foreclosing entity must be one of the parties authorized to foreclose under G. L. c. 183, § 21, and G. L. c. 244, § 14).
The judge did not err in concluding that the securitization documents submitted by the plaintiffs failed to demonstrate that they were the holders of the Ibanez and LaRace mortgages, respectively, at the time of the publication of the notices and the sales. The judge, therefore, did not err in rendering judgments against the plaintiffs and in denying the plaintiffs’ motions to vacate the judgments.20
We now turn briefly to three other arguments raised by the plaintiffs on appeal. First, the plaintiffs initially contended that the assignments in blank executed by Option One, identifying the assignor but not the assignee, not only “evidence[] and confirm[] the assignments that occurred by virtue of the securitization agreements,” but “are effective assignments in their own right.” But in their reply briefs they conceded that the assignments in blank did not constitute a lawful assignment of the mortgages. Their concession is appropriate. We have long held that a conveyance of real property, such as a mortgage, that does not name the assignee conveys nothing and is void; we do not regard an assignment of land in blank as giving legal title in land to the bearer of the assignment. See Flavin v. Morrissey, 327 Mass. 217, 219 (1951); Macurda v. Fuller, 225 Mass. 341, 344 (1916). See also G. L. c. 183, § 3.
Second, the plaintiffs contend that, because they held the mortgage note, they had a sufficient financial interest in the mortgage to allow them to foreclose. In Massachusetts, where a note has been assigned but there is no written assignment of the mortgage underlying the note, the assignment of the note does not carry with it the assignment of the mortgage. Barnes v. Boardman, 149 Mass. 106, 114 (1889). Rather, the holder of the mortgage holds the mortgage in trust for the purchaser of the note, who has an equitable right to obtain an assignment of the mortgage, which may be accomplished by filing an action in court and obtaining an equitable order of assignment. Id. (“In some jurisdictions it is held that the mere transfer of the debt, without any assignment or even mention of the mortgage, carries the mortgage with it, so as to enable the assignee to assert his title in an action at law. . . . This doctrine has not prevailed in Massachusetts, and the tendency of the decisions here has been, that in such cases the mortgagee would hold the legal title in trust for the purchaser of the debt, and that the latter might obtain a conveyance by a bill in equity”). See Young v. Miller, 6 Gray 152, 154 (1856). In the absence of a valid written assignment of a mortgage or a court order of assignment, the mortgage holder remains unchanged. This common-law principle was later incorporated in the statute enacted in 1912 establishing the statutory power of sale, which grants such a power to “the mortgagee or his executors, administrators, successors or assigns,” but not to a party that is the equitable beneficiary of a mortgage held by another. G. L. c. 183, § 21, inserted by St. 1912, c. 502, § 6.
Third, the plaintiffs initially argued that postsale assignments were sufficient to establish their authority to foreclose, and now argue that these assignments are sufficient when taken in conjunction with the evidence of a presale assignment. They argue that the use of postsale assignments was customary in the industry, and point to Title Standard No. 58 (3) issued by the Real Estate Bar Association for Massachusetts, which declares: “A title is not defective by reason of . . . [t]he recording of an Assignment of Mortgage executed either prior, or subsequent, to foreclosure where said Mortgage has been foreclosed, of record, by the Assignee.”21 To the extent that the plaintiffs rely on this title standard for the proposition that an entity that does not hold a mortgage may foreclose on a property, and then cure the cloud on title by a later assignment of a mortgage, their reliance is misplaced because this proposition is contrary to G. L. c. 183, § 21, and G. L. c. 244, § 14. If the plaintiffs did not have their assignments to the Ibanez and LaRace mortgages at the time of the publication of the notices and the sales, they lacked authority to foreclose under G. L. c. 183, § 21, and G. L. c. 244, § 14, and their published claims to be the present holders of the mortgages were false. Nor may a postforeclosure assignment be treated as a pre-foreclosure assignment simply by declaring an “effective date” that precedes the notice of sale and foreclosure, as did Option One’s assignment of the LaRace mortgage to Wells Fargo. Because an assignment of a mortgage is a transfer of legal title, it becomes effective with respect to the power of sale only on the transfer; it cannot become effective before the transfer. See In re Schwartz, supra at 269.
However, we do not disagree with Title Standard No. 58 (3) that, where an assignment is confirmatory of an earlier, valid assignment made prior to the publication of notice and execution of the sale, that confirmatory assignment may be executed and recorded after the foreclosure, and doing so will not make the title defective. A valid assignment of a mortgage gives the holder of that mortgage the statutory power to sell after a default regardless whether the assignment has been recorded. See G. L. c. 183, § 21; MacFarlane v. Thompson, 241 Mass. 486, 489 (1922). Where the earlier assignment is not in recordable form or bears some defect, a written assignment executed after foreclosure that confirms the earlier assignment may be properly recorded. See Bon v. Graves, 216 Mass. 440, 444-445 (1914). A confirmatory assignment, however, cannot confirm an assignment that was not validly made earlier or backdate an assignment being made for the first time. See Scaplen v. Blanchard, 187 Mass. 73, 76 (1904) (confirmatory deed “creates no title” but “takes the place of the original deed, and is evidence of the making of the former conveyance as of the time when it was made”). Where there is no prior valid assignment, a subsequent assignment by the mortgage holder to the note holder is not a confirmatory assignment because there is no earlier written assignment to confirm. In this case, based on the record before the judge, the plaintiffs failed to prove that they obtained valid written assignments of the Ibanez and LaRace mortgages before their foreclosures, so the postforeclosure assignments were not confirmatory of earlier valid assignments.
Finally, we reject the plaintiffs’ request that our ruling be prospective in its application. A prospective ruling is only appropriate, in limited circumstances, when we make a significant change in the common law. See Papadopoulos v. Target Corp., 457 Mass. 368, 384 (2010) (noting “normal rule of retroactivity”); Payton v. Abbott Labs, 386 Mass. 540, 565 (1982). We have not done so here. The legal principles and requirements we set forth are well established in our case law and our statutes. All that has changed is the plaintiffs’ apparent failure to abide by those principles and requirements in the rush to sell mortgage-backed securities.
Conclusion. For the reasons stated, we agree with the judge that the plaintiffs did not demonstrate that they were the holders of the Ibanez and LaRace mortgages at the time that they foreclosed these properties, and therefore failed to demonstrate that they acquired fee simple title to these properties by purchasing them at the foreclosure sale.
Judgments affirmed.
CORDY, J. (concurring, with whom Botsford, J., joins). I concur fully in the opinion of the court, and write separately only to underscore that what is surprising about these cases is not the statement of principles articulated by the court regarding title law and the law of foreclosure in Massachusetts, but rather the utter carelessness with which the plaintiff banks documented the titles to their assets. There is no dispute that the mortgagors of the properties in question had defaulted on their obligations, and that the mortgaged properties were subject to foreclosure. Before commencing such an action, however, the holder of an assigned mortgage needs to take care to ensure that his legal paperwork is in order. Although there was no apparent actual unfairness here to the mortgagors, that is not the point. Foreclosure is a powerful act with significant consequences, and Massachusetts law has always required that it proceed strictly in accord with the statutes that govern it. As the opinion of the court notes, such strict compliance is necessary because Massachusetts is both a title theory State and allows for extrajudicial foreclosure.
The type of sophisticated transactions leading up to the accumulation of the notes and mortgages in question in these cases and their securitization, and, ultimately the sale of mortgaged-backed securities, are not barred nor even burdened by the requirements of Massachusetts law. The plaintiff banks, who brought these cases to clear the titles that they acquired at their own foreclosure sales, have simply failed to prove that the underlying assignments of the mortgages that they allege (and would have) entitled them to foreclose ever existed in any legally cognizable form before they exercised the power of sale that accompanies those assignments. The court’s opinion clearly states that such assignments do not need to be in recordable form or recorded before the foreclosure, but they do have to have been effectuated.
What is more complicated, and not addressed in this opinion, because the issue was not before us, is the effect of the conduct of banks such as the plaintiffs here, on a bona fide third-party purchaser who may have relied on the foreclosure title of the bank and the confirmative assignment and affidavit of foreclosure recorded by the bank subsequent to that foreclosure but prior to the purchase by the third party, especially where the party whose property was foreclosed was in fact in violation of the mortgage covenants, had notice of the foreclosure, and took no action to contest it.
WASHINGTON -- The Federal Reserve has reversed its opposition to new rules reining in foreclosure abuses, and will support stronger regulations on the nation's largest banks, according to a source familiar with the matter.
The Wall Street reform legislation signed into law by President Obama in July 2010 required federal regulators to write new rules governing the broken market for mortgage bonds. Problems in the packaging and sale of mortgage bonds helped inflate the housing bubble and facilitated the sale of predatory loans nationwide. Since banks could push mortgages on borrowers and then sell them to investors, critics say that banks lacked serious incentives to ensure those loans could be repaid.
The FDIC has been pushing hard to ensure that new regulations on the mortgage bond market include clear instructions for how banks handle mortgages-- and under what circumstances they can evict delinquent borrowers. The bank divisions that collect payments from borrowers and implement the foreclosure process-- known as "mortgage servicers"-- have been plagued by rampant problems with fraudulent documentation. This fraud has resulted in everything from illegal fees charged to borrowers to improper evictions.
The Fed had opposed using the mortgage bond rules to crack down on foreclosure abuses, despite pressure from the FDIC. But FDIC General Counsel Michael Krimminger recently told the Fed his agency would not support any new mortgage bond regulations that do not include strong rules forbidding foreclosure abuses. Krimminger told HuffPost that other regulatory agencies are "moving in our direction on the issue."
Krimminger would not specify which agencies were coming around. But a separate source close to the discussions told HuffPost that the Fed has come on board, with systemic risk watchdogs at the central bank sympathetic to Krimminger's position.
Late last month, more than 50 economists, banking experts and financial reform advocates sent regulators a letter urging them to use the mortgage bond rules to create a gold standard for handling mortgages in a responsible fashion. Many of the rules proposed in the letter were very simple standards, like promptly crediting borrower accounts when they make payments on their loans. But mortgage servicers have had significant problems performing these tasks for years, and regulators have not checked them. The Office of the Comptroller of the Currency (OCC), which regulates the largest mortgage servicers, has never issued any public regulatory sanction against a servicer. Current OCC chief John Walsh also said in a recent Congressional hearing that his agency was unaware of foreclosure fraud problems until the media began reporting them.
A cadre of House Democrats lead by Rep. Brad Miller (D-N.C.) has also urged regulators to use the new mortgage bond rules to crack down on foreclosure abuses and encourage loan work-outs.
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Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...
bench craft company reviews bench craft company reviews
'The Daily' iPad <b>News</b> Publication to Debut January 19th - Mac Rumors
Last month, All Things Digital reported that News Corp.'s forthcoming tablet-focused news publication, The Daily, appeared likely to debut sometime the week of January 17th. Forbes has now confirme.
TaxProf Blog: 2011 Tax <b>News</b>
TaxProf Blog provides resources, news, and information for law school tax professors. It is not affiliated with Auto Didactix LLC's TaxProf, a software-based tutorial for law students in the federal income tax course. ...
<b>News</b> Corp. Insiders Talking About Selling MySpace To Yahoo
News Corporation (News Corp) is the world's second-largest media conglomerate (behind The Walt Disney Company) as of 2008 and the world's third largest in entertainment as of 2009. The company's Chairman, Chief Executive. ...