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APR-B4-2806 12:27 FROM: TO: 385 223 7345 P.4/72@ } é cocencare fl xc in the Palm Beach Gardens office of Mortgage Express as a mortgage broker. 3. At all times material to this information, Bank of America was a financial institution whose deposits were insured by the Federal Deposit Insurance Corporation ("FDIC"). 4. At all times material to this information, Republic Consumer Lending Group, a subsidiary of Republic National Bank of New York, was a corporation engaged in the business of private mortgage lending. Republic Consumer Lending Group later merged with HSBC Bank USA, in the State of New York. , 5. AMWAY Claes ekevial be Kids indointion, “ite Savings Bank was a bank whose deposits were insured by the Federal Deposit Insurance Corporation. THE SCHEME AND ARTIFICE TO DEFRAUD 6 It was the object of the scheme and artifice to defraud that the defendatit would and did obtain mortgage financing for himself and for customers of Mortgage Express by means of false and fraudulent pretenses. As a result, the defendant would obtain monies and mortgage broker commissions in connection with fraudulently procured loans. 8. In order to procure mortgage financing for himself and for customers of Mortgage Express, on various occasions, the defendant did knowingly and willfully submit false and fraudulent information 2 07/26/17 1 Page 3 Public Records Request No.: 17-295 DOJ-OGR-00031524