On January 9, 2008, the Board of Governors of the Federal Reserve System (“Board”) proposed significant amendments to Regulation Z, which are discussed in this memorandum. We believe these proposed amendments will have a dramatic impact on the way mortgage lending is conducted if the Board adopts them, as proposed. TEXT OF PROPOSED AMENDMENTS: The text of the proposed amendments and their proposed Official Staff Interpretations can be printed from the Federal Register website at: http://www.gpoaccess.gov/nara/index.html. You may also obtain a copy by clicking on http://www.federalreserve.gov/newsevents/press/bcreg/20071218a.htm.

Complete Memorandum