Foreclosure On Equity120308

EAGLE 9® UCC Division

FIRST AMERICANTITLE INSURANCE COMPANY


FORECLOSURE ON EQUITY INTERESTS

INREAL ESTATE MEZZANINELENDING TRANSACTIONS

EAGLE 9® UCC Division Our Mission

Cover foreclosure of Article 9 security interests on equity collateral in real estate mezzanine lending.


• The potential liability exposure associated with becoming the proud owner of the borrower’s distressed business following the foreclosure of a lien on an equity interest (an equity play).– Piercing the Veil– Equitable Subordination– Management Risks– Fiduciary (Competence and

loyalty)– Duty to Creditors

What We Are Not Exploring in Depth

EAGLE 9® UCC Division Other Sources

• Lynn L. Soukup, Securities Law and the UCC: When Godzilla Meets Bambi, Uniform Commercial Code Law Journal [Vol. 38, #1].

• Dennis B. Arnold, Enforcing Security Interests in Membership Interests and Partnership Interests Under Revised Article 9 of the Uniform Commercial Code, Commercial Real Estate Finance 2007.

EAGLE 9® UCC Division Other Sources

• John C. Murray, Carveouts to Nonrecourse Loans: Are They Enforceable?

• Donald W. Glazer and Jonathan C. Lipson, Courting the Suicide King, Closing Opinions and Lawyer Liability, Business law Today, Volume 17, No. 4,March/April 2008.


But Now:

What is mezzanine lending?


What is Mezzanine Lending?“Mezzanine lending. . .means lending to a borrowing entity or group of entities that directly or indirectly owns a real property-owning entity, which debt is secured by a perfected first security interest in the mezzanine borrower’s pledged ownership interests in the property owner”

(Report by Moody’s Investors Service titled “US CMBS and CRE CDO: Moody’s Approach to Rating Commercial Real Estate Mezzanine Loans,” the “Moody’s Report,” page 3)

EAGLE 9® UCC Division What is Mezzanine Lending?

“Financing secured by pledges of ownership interests in the real property owning entity rather than by security in the real property itself…” (Moody’s Report page 2) (emphasis in original)

EAGLE 9® UCC Division What is Mezzanine Lending?

THEREFORE A PERSONAL PROPERTY SECURED

TRANSACTION!


• Finances difference between senior mortgage and amount investor wants to invest–Senior Mortgage: 40 - 70% LTV–Mezzanine Financing: up to 90%

LTV

What is Mezzanine Lending?


RRE E TTUURRNN

RISKRISK

DEBTDEBT

EQUITYEQUITY

Mezzanine Mezzanine FinancingFinancing



Generally: a non-mortgage form of subordinate financing (replaces traditional 2nd mortgage)

– No lien against real estate

– Lien/ownership is in equity interests in entity which owns the real estate

– Upon foreclosure mezzanine lender owns the entity and takes over mortgage borrower



Developed after real estate foreclosure debacles in early 1990’s cause by junior lenders:

– Prevents delays on foreclosure, maybe

– Eliminates forced bankruptcy of mortgage borrower

– Requirements are set by rating agencies for first mortgage to qualify for securitization pools



Intercreditor Agreement

In 2002, CMBS World published a “suggested standard form” of Intercreditor Agreement – the “CMSA form” (also the “Dechert form”). The form is “credit neutral” platform against which Moody’s weighs modifications. (Moody’s Report page 6)


Real PropertyLender

Owner ofReal Property

MezzanineLender

AB

Mortgage Loan

Equity Secured Loans

Equity Owners

Mezzanine Lending


PropertyLender

Owner ofProperty

MezzanineLender #1

A B

Mortgage Loan

Equity Owners

Co-Borrowers

DC EMezzanineLender #2

F G HMezzanineLender #3

IMezzanineLender #4

Mezzanine Loans

Mezzanine Lending


Lender Borrower

A B

Asset Based Loan

Equity Secured Guarantees

Equity Owners

PLEDGED EQUITY LENDING

Law is the Same

EAGLE 9® UCC Division A GUIDE TO THINKING ABOUT PERFECTION

• Step 1: Does Article 9 Apply?• Step 2: Attachment• Step 3: Categorize the Collateral• Step 4: Perfection Step

• Filing (§9-310)• Perfection under non-Article 9 law (§9-311(a))• Possession (§9-313)• Control (§§9-314, 9-104, 9-106, 8-106)

• Step 5: Priority Consequences


Perfection of liens (security interests) in equity interest collateral.

Lien Perfection


US CMBS and CRE CDO: Moody’s Approach to Rating Commercial Real Estate

Mezzanine Loans

“Moody’s expects that 100% of the beneficial ownership interests in the property owning entity will be pledged as collateral, so that any foreclosure of the mezzanine loan will produce a transfer of all of the equity interests in the property owner, leaving behind no minority interests.”


“Therefore, Moody’s expects that mortgage loan borrowers will irrevocably “opt-in” to Article 8 of the UCC and will certificate the partnership or LLC membership interest that will be pledged to the mezzanine lender.”

Moody’s Report


“UCC-1 financing statements should additionally be filed, as “fail-safe” protection.”

Moody’s Report


The mortgage borrower’s organizational documents should have provisions prohibiting both the issuance of additional interests and opting-out of Article 8 without the lender’s written consent.

Moody’s Report


“Therefore, Moody’s generally expects that mezzanine loans presented for rating will have the benefit of … in all cases … of a ‘UCC insurance policy’ where available.”

Moody’s Report


US CMBS and CRE CDO: Moody’s Approach to Rating Commercial Real Estate

Mezzanine Loans

Pledge of 100% of the equityOpt In to Article 8Certificate the EquityFile a Financing StatementControl the ability to Opt Out

– hardwire or proxyUCC Insurance


NEED TO CONSIDER NOT ONLY

• SECURED CREDITOR STATUS UNDER ARTICLE 9 OF THE UCC;

BUT ALSO

• PROTECTED PURCHASER STATUS UNDER ARTICLE 8 OF THE UCC


Protected Purchaser Status and Equity Ownership Coverage

LENDER’S POLICY

Mezzanine Endorsement – Primary Obligor

Pledged Equity Endorsement – Secondary Obligor

BUYER’S POLICY Equity Ownership Endorsement


NEMO DAT QUOD NON HABET*

*“No man can give what he does not have”


EXCEPTIONS TO NEMO DAT:◦ Negotiable Promissory Notes◦ Negotiable Bills of Lading◦ Securities under Article 8 – if a Protected

Purchaser


“In addition to acquiring

the rights of a purchaser,

a Protected Purchaser

also acquires its interest

in the security

free of any adverse claim.”

§8-303(b)


FIRST STEP IS TO BE A SECURED CREDITOR BY CONTROL OF A SECURITY UNDER ARTICLE 8 and INVESTMENT PROPERTY UNDER ARTICLE 9

EAGLE 9® UCC DivisionNOTE: If entity subsequently opts-in to be a security under Article 8 (no way to prevent), then Protected Purchaser has priority in security over first lien-holder who perfected by filing!

EntityEntity Ownership Ownership

InterestsInterests

Is it a security under Art. 8?

Perfection by Filing Perfection by Filing Financing StatementFinancing Statement

Perfection by Perfection by Control Control

AgreementAgreement

Is it certificated or uncertificated ?

NO

YESCertificated

Uncertificated

WINS over

filing!

Perfection by Perfection by Possession + Possession + Endorsement Endorsement

ControlControl


THEN BE A PROTECTED PURCHASER UNDER

ARTICLE 8


Mezz/Pledged EquityEndorsement

Section 8303 of the U.C.C. defines a “Protected Purchaser” as a purchaser of a security or an interest who:

i. Gives value.

ii. Does not have notice of any adverse claim to the security.

iii. Obtains control of the security.


ARTICLE 8 ARTICLE 9

Opt-In to Article 8 – LLC or Partnership Interest

a Security

Investment Property

Protected Purchaser Perfection by Control

I WIN!!!!!!

ARTICLE 8 and ARTICLE 9 - INTERRELATIONSHIP


Equity Owner –California LLC

Property Owner –Delaware LLC

Ultimate Parent

The Property

First MezzanineLender Loan Secured by

Pledge of EquityIn Delaware Sub

Lender Perfects SecurityInterest in Pledged Equity by Filing UCC-1 with CASOS

Step #1

A Case Study


Old Equity Owner –

California LLC

Property Owner – Delaware LLC

Ultimate Parent

The Property

First Mezzanine

Lender

NewEquity Owner-Delaware LLC1.3.

1. Sells Equity Ownership in Sub to Sister Sub for $100,000,000

SecondMezzanine

Lender2.

2. Provides New Mezzanine LoanSecured by EquityOwnership in Del. Sub – Perfects by Control and Protected Purchaser

3. Pays Off First Mezzanine Lender with Proceeds of Mezz Loan from Second Mezzanine Lender

Step #2

A Case Study


First Mezzanine Lender Sues OldEquity Owner for Conversion BasedOn Fraudulent Conveyance Alleging Property Worth $400,000,000 and Wants $2,000,000 kicker

Old Equity Owner –

California LLC

Property Owner – Delaware LLC

Ultimate Parent

The Property

First Mezzanine

Lender

NewEquity Owner-Delaware LLC

SecondMezzanine

Lender

Step #3

A Case Study


FORECLOSURE

EAGLE 9® UCC Division Initial Steps –Evaluate Facts

• Evaluate Facts

• Review Loan Documentation and Deal Structure

> Confirm perfection of security interest

> Confirm that you have a pledge of 100% of the equity

> Check any requirements imposed by lender

> Review guaranties; have other collateral?

> Is there a lockbox or blocked account?

> Determine which state’s UCC governs the exercise of the mezzanine lender’s remedies

> Understand status of senior loan

EAGLE 9® UCC Division Evaluate Facts

•Monetary default: interest, principal, other payments•Non-monetary default: covenants, other•Cure periods•Always good practice to provide mezzanine borrower

with written notice of default•Written notice may be required to commence

cure periods

Consult with local counsel re state specific issues/concerns (transfer taxes etc.)

Obtain updated UCC searches

Confirm that an event of default has occurred

EAGLE 9® UCC Division Evaluate Facts

Review senior loan documents – if mezzanine lender acquires the mezzanine collateral it will become the direct or indirect owner of the property/owner mortgage borrower and will be subject to the terms of the senior loan documents

Review other material contracts and agreements such as ground leases and material contracts pertaining to the underlying property.

EAGLE 9® UCC Division Intercreditor Issues

The intercreditor agreement governs the relationship between the senior and junior lenders– Cross default provisions– Junior lender’s right to cure senior loan defaults– Junior lender’s right to purchase senior loans –

mortgage and other tranches of mez– Can mezzanine lender foreclose on mezzanine loan

collateral• Qualified Transferee• Replacement guaranties• Replacement of property managers• Delivery of opinions• Cure of senior loan defaults (strategy to stave off

foreclosure)

EAGLE 9® UCC Division Confirm Perfection of Security Interest

• Review organizational documents of the entity owned by the mezzanine to see if election to “opt-in” to Article 8 has been correctly made and whether or not the equity inertest has been certificated.

• Depending on the scope of collateral and whether Article 8 applies, confirm that UCC financing statements have been filed in the appropriate jurisdictions. The appropriate jurisdiction is usually the jurisdiction of organization.

• If the entity owned by the mezzanine has opted in to Article 8, determine if “control” has been obtained.

EAGLE 9® UCC Division Other Parties

• Are there any other interested parties?– Guarantors– Pledgors– Other creditors – UCC searches– Any other parties that have requested notice

of foreclosure sale


• Foreclosure by Public Sale

• Foreclosure by Private Sale

• Retention of Collateral in Satisfaction of the Debt

• Judicial Enforcement

• Collection Rights under UCC Section 9-607

Methods of Foreclosure


1. Analogies to real property law don’t work – as is generally true:

• foreclosure cuts off right of redemption (§9-623(c))

• rights of good faith transferee (§9-617(b))

2. Secured creditor rights upon default (including foreclosure) are covered in Part 6 of Article 9.

Foreclosure 101:


Judicial sale Article 9 sale

Purpose

By whom?

Legal standard?

When final?

Judgment for deficiency?

Sale Procedures Compared



Purpose Enforce mortgage

Protect “equity”

Maybe fix deficiency

By whom?

Legal standard?

When final?








Enforce SI

Protect “surplus”


By whom?

Legal standard?

When final?








Enforce SI



By whom? Sheriff, clerk

Legal standard?

When final?








Enforce SI



By whom? Sheriff, clerk Secured party

Legal standard?

When final?








Enforce SI




Legal standard? Fixed procedural

requirements

When final?








Enforce SI





requirements

Commercially reasonable

When final?








Enforce SI





requirements


When final? On confirmation








Enforce SI





requirements


When final? On confirmation Upon sale








Enforce SI





requirements




Varied rules







Enforce SI





requirements




Varied rules If procedure OK, and secured is not buyer







Enforce SI





requirements




Varied rules If procedure OK, and secured is not buyer


EAGLE 9® UCC Division Public vs. Private UCC Foreclosure Sales

Public Sale –

• Not defined

• Meaningful opportunity for competitive bidding

• Some form of advertising and notice to maximize public participation

• Commercially Reasonable

EAGLE 9® UCC Division Public vs. Private UCC Foreclosure Sales

Limits on the right of the secured creditor to purchase collateral at a private sale (§9-610(c)).– No limits in a public

sale.– Only collateral sold on

a recognized market/subject to widely distributed standard price quotes (publicly traded stock) can be purchased at a private sale by the secured creditor.


Notice:– Notification provisions of §§9-611-613.– Who receives notice of the sale. (§9-611)

• The Debtor, any secondary obligor, other secured creditors, and others requesting notice.

• While not technically required, notice to parties that have expressed an interest in acquiring the collateral may bear on whether the sale was commercially reasonable.

Public/Private Sale:


Notice:– Contents of notice of sale: “time and

place of a public disposition” vs. “time after which” (§9-613).

– Timeliness of notice:10 day safe harbor (§9-612).

– UCC Foreclosure Notice Insurance Policy™ (pending).


EAGLE 9® UCC Division Content of Notice

§9-613 provides that notice is sufficient if it:– Describes the debtor and the secured party– Describes the collateral being sold– States the method of intended disposition– States that the debtor is entitled to an accounting of

the unpaid indebtedness and states the charge, if any, for the accounting

– States the time and place of public disposition or the time after which any other disposition will be made

EAGLE 9® UCC DivisionWhere to Advertise

• Depends on the type of collateral

• Newspapers of general circulation

• Trade journals

• Location of likely bidders

• Specialized markets


• Private Sale Significantly Cheaper

• Commercially Reasonable Notice AND Commercially Reasonable Sale

• “Qualified Transferee”

• Rights of Good Faith Transferee (§9-617)



§9-610(b):Every aspect of a disposition of collateral, including the method, manner, time, place, and other terms, must be commercially reasonable

Commercially Reasonable Sale


§9-627(b)(3):Otherwise in conformity with reasonable commercially practices among dealers in the type of property that was the subject of the disposition.



§9-627(a):

The fact that a greater price could have been obtained ...is not itself sufficient to preclude the secured party from establishing that the ...[foreclosure] was made in a commercially reasonable manner


EAGLE 9® UCC Division Commercial Reasonableness

A commercially reasonable sale may include the following:– Marketing method– Advertising in trade publications and newspapers– Retention of brokers– Electronic forum– Providing property profiles to prospective

purchasers and access to subject property– “war room” – provide sufficient due diligence materials

and time to allow potential buyers to review– Disclaimer of warranties (§9-610(e))– Appropriate UCC insurance

EAGLE 9® UCC Division Commercial Reasonableness

Due Diligence Materials (to the extent available and not confidential), such as:

• information pertaining to the mortgage and other senior loans

• rent roll

• title report

• survey and structural and environmental assessments


§9-627(c)(1):

A collection, enforcement, disposition, or acceptance is commercially reasonable if it has been approved in a judicial proceeding.



MORAL: A foreclosing mezzanine lender should make sure that at each point in the foreclosure process its actions are carefully considered to minimize the chances of a challenge for lack of commercial reasonableness.



• Partial vs. Full Satisfaction – affirmative consent vs.

passive acceptance (§9-620)

• Notice (§9-621)• Acceptance – debtor and others (§9-620)

• Best way to go if Debtor consents

Strict Foreclosure:


Donald J. Rapson commented that strict foreclosure “provides a method of enforcement that is nonadversarial, requires lower transaction costs, and is

not likely to result in litigation.”*

* Default and Enforcement of Security Interests Under Revised Article 9, 74 Chi.-Kent L. Rev. 893. 923 (1999).


Notification of Proposal (§9-621)* -

• any person with an interest in the collateral who has notified the Secured Party;

• any other lienholder that, 10 days before the Debtor consented to the acceptance, held a lien on the collateral perfected by the filing of a Financing Statement; and

• any other secured party that, 10 days before the Debtor consented to the acceptance, held a security interest in the collateral perfected by compliance with a statute, regulation, or treaty described in §9-311(a).

• In addition, if in partial satisfaction, to any secondary obligor.

*UCC Foreclosure Notice Insurance Policy™ (pending)

Strict Foreclosure:


Who must consent:

• Debtor under §9-620

• Person to whom notice is required under §9-621

• Any other person holding a subordinate interest in the collateral

Strict Foreclosure:


• Strategic Advantages to Secured Party

• Debtor’s Strategic Assertion of

Objection to Acceptance

Strict Foreclosure:


Deed in lieu Acceptance of Collateral, § 9-620

System

Purpose

Formal requirements

Consumer exceptions

Settlement Procedures Compared



System Real estate

Purpose

Formal requirements

Consumer exceptions




System Real estate Personal property

Purpose

Formal requirements

Consumer exceptions





Purpose Settlement that avoids foreclosure

Formal requirements

Consumer exceptions






Settlement that avoids foreclosure

Formal requirements

Consumer exceptions







Formal requirements

Deed

Consumer exceptions







Formal requirements

Deed 1. Authenticated agree-ment partial satisfaction

2. Lack of objection if in full satisfaction

Consumer exceptions







Formal requirements



Consumer exceptions

No







Formal requirements



Consumer exceptions

No 1. Waiver needed if debtor has paid 60% 2. No partial satisfaction3. Not while debtor has the collateral







Formal requirements



Consumer exceptions

No 1. Waiver needed if debtor has paid 60% 2. No partial satisfaction3. Not while debtor has the collateral



Lack of Objection

(only for full satisfaction)

Actual Agreement(for partial or full satisfaction)

Procedures for Acceptance (Consent)


Lack of Objection



Secured party consent: Secured party sends unconditional proposal to accept in full satisfaction §9-620(b)(1).



Lack of Objection




Debtor consent:Secured party receives no objection to proposal within 20 days, § 9-620(c)(2)(C).



Lack of Objection




Secured party consent: Secured party consents in an authenticated record §9-620(b)(1).




Lack of Objection






Debtor consent: Debtor agrees to terms in a record authenticated after default, § 9-620(c)(1).



Lack of Objection






Debtor consent: Debtor agrees to terms in a record authenticated after default, § 9-620(c)(1).



• Discharges the security interest under which the disposition is made;

• Transfers to a transferee for value all of the debtor’s rights in the collateral; and

• Discharges any subordinate security interest or other subordinate lien.

Results of Foreclosure:


• In the good old days: – Madrid to BFP vs. RTC, 511 US

531 (1994)(regularly conducted, non collusive sale conforming to state law is not avoidable).

• Today:– Krohn v. Sweeheart Properties,

203 Ariz. 205, 52 P3d 774 (2002)(sale price is grossly inadequate).

– §9-615(f) calculation of surplus or deficiency when the secured party or a person related to the secured party acquires the collateral through foreclosure.

• Be commercially reasonable (§9-610(b).

Setting Aside Foreclosures


– Read Lynn Soukup’s article.

– Ability of lender to acquire equity interests at public or private sale (§9-610(c)).

– No action letters and other securities law challenges to a secured lender that is attempting to foreclose on stock of a public company pledged to secure a loan.

– UCC Article 8 implications for the lien interest itself (protected purchaser status, etc.).

Foreclosure On Equity:

EAGLE 9® UCC DivisionForeclosure On Equity:

NOTE #1: If 100% of the equity is not in play, without the necessary consents from other partners or members, the successful purchaser at a foreclosure sale may not be able to succeed to the right or powers of a partner or member and is only entitled to receive proceeds and distributions.

EAGLE 9® UCC DivisionForeclosure On Equity:

NOTE #2: Complexities may arise due toi the “carving up” of the capital structure, including conflicts of interest between a servicer/collateral agent that also holds an interest in a mortgage or mezzanine tranche and another holder of an interest in a mezzanine tranche.

EAGLE 9® UCC Division Foreclosure On Equity:

AND THEN THE MEZZANINE BORROWER

FILES BANKRUPTCY!

FINAL THOUGHTS IF WE HAVE TIME

EAGLE 9® UCC Division Foreclosure On Equity:

BUT REMEMBER “BAD BOY”

CARVEOUTS TO NONRECOURSE

LIABILITY!

EAGLE 9® UCC Division Foreclosure Through Bankruptcy & Receiverships

• Stay of foreclosure in a bankruptcy case.– Does stay apply to foreclosure of

equity interests?

• Foreclosure through a §363 sale or plan of reorganization in a bankruptcy case.

• Power of receiver to sell assets (in lieu of a foreclosure)

• Retention of foreclosure rights by a secured creditor who moves for the appointment of a receiver.

• Use of professionals to assist with the disposition of collateral.


• Debt play• Equity play

Recovery Approaches in General


“Going Concern” Recoveries (Debt Play)

may exceed breakup liquidation value.

• Cooperative Chapter 11 / plan• Cooperative Chapter 11 / 363 sale• Foreclosure to third party

Debt Play:


Section 363 Sales

Increased Scrutiny for Sales

to Insiders


In re Medical Software Solutions, 286 B.R. 431 (2002)

• Owner/Lender case (VC)

• Sought approval of §363 sale to the VC

• Debtor requested examiner

• Examiner reported no inequitable conduct, loans made in good faith

Section 363 Sales


In re Medical Software Solutions, 286 B.R. 431 (2002)

• Equitable subordination rejected

• Recharacterization rejected

• §363 sale approved as having sound business reason and being undertaken in good faith

Section 363 Sales


LENDER as OWNER:When Lender acquires 100% of the equity of Debtor as a

recovery strategy.

Equity Play:


Why Acquire Equity of the Debtor?

• Cut off owners, set up other remedies• Complex assets re: transfer• Non-assignable assets• Unencumbered assets• Control for rehabilitation – Mortgage

Borrower• Absence of other collateral• Absence of other permitted remedies

Equity Play:


“Going Concern” Recoveries (Equity)

• Foreclose on equity

• Convert debt

Equity Play:


Risks of Lender/Owner

Piercing the Veil

Equitable Subordination

Management Risks

Equity Play:


Equitable Subordination §510(c)

...the court may…under principles of equitable subordination, subordinate for purposes of distribution all or part of an allowed claim to all or part of another allowed claim…


Mobile Steel

• Inequitable conduct

• Injury to other creditors

• Not inconsistent with other Bankruptcy Code provisions



• Defined BK §101(31)

• More scrutiny of insiders v. non-insiders

• “Material evidence” shifts the burden to the insider

• The insider has burden of showing its good faith and the fairness of its conduct



Inequitable Conduct

(i) fraud, illegality or breach of fiduciary duties by the creditor,

(ii) use of the debtor as a mere instrumentality or alter ego



Remedies Under Equitable Subordination

• Scope of subordination

• Amount of subordination

• Burden of proof to limit subordination



Lender/Owner Management Risk

Fiduciary Duties of Directors


• Fiduciary (competence and loyalty)

• Business Judgment Rule

• Presumption of Regularity



• Duty to creditors• Loyalty emphasis• Some courts extend

to duty of competence, subject to business judgment rule



Potential Appointment of Trustee for “Cause”

Includes without limitation fraud, dishonesty, incompetency or gross mismanagement

HOSTILE BORROWER

EAGLE 9® UCC Division Cause Also Includes:

• Materiality of misconduct • Evenhandedness in dealings with insiders or

affiliated entities vis-a-vis others • Pre-petition voidable preferences or fraudulent

transfers• Unwillingness or inability of management to

pursue estate causes of action• Conflicts of interest interfering with management’s

ability to fulfill fiduciary duties to the debtor


UCC EAGLE 9®

NEW PROGRAMS, NEW SOLUTIONS!


• Domain Name (URL): www.eagle9.com• E-mail Address: [email protected]• Toll Free Number: (800) 700-1191• UCC Division Legal Team:

– Randy Scott, President & Counsel– Jim Prendergast, Senior Vice President

and General Counsel– Brad Gibson, Associate General Counsel

RESOURCES


QUESTIONS

????


THANK YOU


CONTACT COLORADO NCS

Curtsey of

Colorado NCS Office

8310 S. Valley Hwy, Suite 135

Englewood, CO 80112

303-704-1878

[email protected]

Economy & Finance

Foreclosure On Equity120308