Bulletin: FL000020

Dear Associates:

Recently the two men and the corporation recited above were prosecuted on a land fraud case. The case particularly involved "flipping" of properties in that the flipping was done in order to inflate property values in order to defraud several banks to lend money on the property with the inflated values being sufficient to divert money to the owners so that they eventually ended up with 200 acres of beachfront land free and clear of liens. The two men have been convicted an sentenced to nine years in prison each pending appeal.

You are cautioned first to avoid doing any transactions with these names in the chain of title. Should you come across any such transaction, do not undertake these transactions without approval of either Harold Hickman or the Legal Department.

You are further cautioned to be extremely careful in any transactions that involve 'flipping" of land as there is a possibility that we may later be accused of participating in a fraud on a bank even though that would not be the case. Accordingly, if you are asked to handle any transaction which involves a "flip", it is imperative that the lender involved be advised in writing that there is a "flip" and that the lender acknowledge it has been advised of a "flip", has examined the transaction and wishes to proceed. There is nothing inherently improper about a "flip". The only issue being addressed is that the transaction be done with knowledge of all parties involved, most particularly a lender we are insuring or the second purchaser in a "flip".