Thursday, March 31, 2016
Was Your Mortgage Loan Sold to Another by Bank of America During a Trial Modification?
If you are an Indiana resident whose Bank of America loan was transferred to another lender (possibly Seterus or Caliber) during or after a trial modification, and if you don't already have a lawyer, please contact me. If you are outside Indiana, find a NACA attorney at www.consumeradvocates.org. Don't delay, these cases are touchy and time-sensitive.
Another IRS Scam
I received a call on my cell phone that caller ID listed as (619) 548-2875. The recorded voice said it was a call from the IRS, and the were going to file a lawsuit against me. This is, of course, a scam. If you get one of these calls, don't call them back, don't do anything. Don't even call me. This type of scammer is virtually impossible to take private action against. They operate in a way that they don't have any assets that you can get to even if you can find out who to sue. You can report them to the F.B.I.'s Internet Crime Complaint Center (known on the web as IC3) at www.ic3.gov.
Wednesday, March 30, 2016
Some thoughts on Mortgage Foreclosure Defense - What makes a successful Case?
I'm just completing several mortgage foreclosure defense cases, and I'm pondering the lessons learned.. Mortgage foreclosure defense was never a huge part of my practice, though I am one of the few Indiana lawyers that take such cases, but during the surge of foreclosure filings following the great recession, I handled my share. As I think about it, every foreclosure defense case I've had has been unique, and I think it is because people who find themselves sued for foreclosure are in that position because life has put them in extreme circumstances. Usually the circumstances couldn't have been predicted by the homeowner. When you faced with foreclosure, and you are looking for a foreclosure lawyer, you should look for a lawyer who will take the time to listen to you, and you should take the time to tell the lawyer what your goals and expectations are. You should also listen to the lawyer though, especially if the lawyer believes your goals are not realistic, and may not even be in your best interest.
One lesson that my cases have taught me is that all houses aren't worth saving. If you sign a modification that commits you to paying well more than the house is worth, you should think long and hard about doing it. When you sign a mortgage modification that puts principal balance on the back end of the loan, even if your payment is workable, the added principal balance hurts your net worth. You may be wedded to that home for years because your modified loan is under water. You won't be able to sell the house without defaulting on the loan, and defaulting on the loan may kill your chance of buying another house.
It's normal not to be decided when you are sued for foreclosure whether the house can or should be saved. In that case, hire an attorney and start the modification relief request process. You don't need to make up your mind until there is an offer on the table. In the meantime, contesting the foreclosure and requesting mortgage relief can buy you time that you need to make up your mind and figure out what to do.
I have learned to be careful taking cases from clients who have been employed but have not been making payments on the house for a year or more. If you haven't made any housing payments for over a year, and you are employed, then in that year, absent very extenuating circumstances, you should have saved up a pretty good chunk of money. If you didn't save anything, the odds are not good that you will be able to make your modification payments if the loan is modified. The bottom line is that when you go to see an attorney about foreclosure defense, you need to be ready to explain what you've done with your money since you stopped making mortgage payments. If you can't answer that question, the attorney might not even be doing you a favor if he/she takes your case.
Another lesson I've learned is that different family members may have different ideas concerning whether it is best to take extraordinary measures to save the house versus moving on. You need to have a candid conversation. This is especially true when the assets and income of different family members are needed to modify a mortgage. You should think twice about putting a young adult son or daughter on hook for a modified loan of a home with no equity. Young adults often have to move to find new jobs. When your son or daughter can't move because he/she can't sell the house, it may be be a real career-killer. Similarly, getting cash from retired or soon to be retired parents may not be a good idea, especially when that cash goes to pay arrearage and cost of foreclosure. That money vanishes as soon as you pay it, because it isn't covered by any value in the property.
At least half of the people who have hired me for mortgage defense came to me after spending thousands of dollars on a "paper mill" mortgage relief firm first. Don't hire a mortgage relief firm that says "we have lawyers". You don't care if THEY have lawyers, you want one who represents YOU. No lawyer can represent you and the mortgage relief company too. The National Association of Consumer Advocates can refer you to a NACA member consumer lawyer who can represent YOU. Usually it will be cheaper than hiring one of the paper mill companies. For a referral, go to www.consumeradvocates.org. Every attorney seems to have a different way of getting paid in mortgage defense cases. When I take a foreclosure defense case, I typically charge an attorney fee paid in monthly installments based on what I think a likely modified payment will be. I work against the retainer on an hourly fee bases. When I do cases like this my fees are usually less both up front and total than the mortgage relief scammers, and usually the total fee is less than what a typical 7% real estate agents commission would be to sell the home. When I charge fees in this manner, if the client can't keep up the attorney fee payment, I know the client would have a hard time making the mortgage payment.
A lesson that I already knew is that there's no such thing as a "free house". You'll see all these postings on the internet about "produce the note". They'll tell you that mortgage companies that can't present an original promissory note or assignment can't foreclose on you, and that beating them is a slam dunk. I can't say that it is impossible to win on a present the note case but it is unlikely, and if you win, it will be only after a tough fight and lots and lots of attorney hours, time that you'd have to pay for. I've had lots of people call me because they wanted their mortgage company to produce the note. Not one of them have wanted to pay for the hours necessary to work up that kind of defense.
So i'm ready to answer the question of what makes a successful mortgage foreclosure case. The answer is that it depends upon the client's situation in life. If they client doesn't have the money to pay for the house and the house's upkeep, then you are best working out a deal for enough time in the property for the client to save some money and obtain alternate housing. If the client has enough cash flow to make a reasonable house payment and want's to stay in the house for a long time, then it's usually best to get a modification sufficient for the client to stay in the house at a payment he/she/they can afford. If the client is part of a family with different interests and objectives, it is best to get the entire family to talk about the situation honestly. The delay inherent in the mortgage foreclosure process amounts to a subsidy of many thousands of dollars. If the family can make the most of this, they can usually arrange a soft landing, often in housing that they like better than the original home.
One lesson that my cases have taught me is that all houses aren't worth saving. If you sign a modification that commits you to paying well more than the house is worth, you should think long and hard about doing it. When you sign a mortgage modification that puts principal balance on the back end of the loan, even if your payment is workable, the added principal balance hurts your net worth. You may be wedded to that home for years because your modified loan is under water. You won't be able to sell the house without defaulting on the loan, and defaulting on the loan may kill your chance of buying another house.
It's normal not to be decided when you are sued for foreclosure whether the house can or should be saved. In that case, hire an attorney and start the modification relief request process. You don't need to make up your mind until there is an offer on the table. In the meantime, contesting the foreclosure and requesting mortgage relief can buy you time that you need to make up your mind and figure out what to do.
I have learned to be careful taking cases from clients who have been employed but have not been making payments on the house for a year or more. If you haven't made any housing payments for over a year, and you are employed, then in that year, absent very extenuating circumstances, you should have saved up a pretty good chunk of money. If you didn't save anything, the odds are not good that you will be able to make your modification payments if the loan is modified. The bottom line is that when you go to see an attorney about foreclosure defense, you need to be ready to explain what you've done with your money since you stopped making mortgage payments. If you can't answer that question, the attorney might not even be doing you a favor if he/she takes your case.
Another lesson I've learned is that different family members may have different ideas concerning whether it is best to take extraordinary measures to save the house versus moving on. You need to have a candid conversation. This is especially true when the assets and income of different family members are needed to modify a mortgage. You should think twice about putting a young adult son or daughter on hook for a modified loan of a home with no equity. Young adults often have to move to find new jobs. When your son or daughter can't move because he/she can't sell the house, it may be be a real career-killer. Similarly, getting cash from retired or soon to be retired parents may not be a good idea, especially when that cash goes to pay arrearage and cost of foreclosure. That money vanishes as soon as you pay it, because it isn't covered by any value in the property.
At least half of the people who have hired me for mortgage defense came to me after spending thousands of dollars on a "paper mill" mortgage relief firm first. Don't hire a mortgage relief firm that says "we have lawyers". You don't care if THEY have lawyers, you want one who represents YOU. No lawyer can represent you and the mortgage relief company too. The National Association of Consumer Advocates can refer you to a NACA member consumer lawyer who can represent YOU. Usually it will be cheaper than hiring one of the paper mill companies. For a referral, go to www.consumeradvocates.org. Every attorney seems to have a different way of getting paid in mortgage defense cases. When I take a foreclosure defense case, I typically charge an attorney fee paid in monthly installments based on what I think a likely modified payment will be. I work against the retainer on an hourly fee bases. When I do cases like this my fees are usually less both up front and total than the mortgage relief scammers, and usually the total fee is less than what a typical 7% real estate agents commission would be to sell the home. When I charge fees in this manner, if the client can't keep up the attorney fee payment, I know the client would have a hard time making the mortgage payment.
A lesson that I already knew is that there's no such thing as a "free house". You'll see all these postings on the internet about "produce the note". They'll tell you that mortgage companies that can't present an original promissory note or assignment can't foreclose on you, and that beating them is a slam dunk. I can't say that it is impossible to win on a present the note case but it is unlikely, and if you win, it will be only after a tough fight and lots and lots of attorney hours, time that you'd have to pay for. I've had lots of people call me because they wanted their mortgage company to produce the note. Not one of them have wanted to pay for the hours necessary to work up that kind of defense.
So i'm ready to answer the question of what makes a successful mortgage foreclosure case. The answer is that it depends upon the client's situation in life. If they client doesn't have the money to pay for the house and the house's upkeep, then you are best working out a deal for enough time in the property for the client to save some money and obtain alternate housing. If the client has enough cash flow to make a reasonable house payment and want's to stay in the house for a long time, then it's usually best to get a modification sufficient for the client to stay in the house at a payment he/she/they can afford. If the client is part of a family with different interests and objectives, it is best to get the entire family to talk about the situation honestly. The delay inherent in the mortgage foreclosure process amounts to a subsidy of many thousands of dollars. If the family can make the most of this, they can usually arrange a soft landing, often in housing that they like better than the original home.
Sunday, March 27, 2016
The Return of the Fake Bill
We recently received the correspondence below at my house. My wife and I have subscribed to National Geographic as long as we've been married - over 25 years; so when received the letter below, we assumed it was a reminder notice from National Geographic Magazine.
"Notice of Continuation" in big bold letters. What else were we to believe? Well, if you look at the bottom, in smaller, thinner red print, you can see "This is an offer from an independent agent, not a bill."
On the back, they repeat that "The offer that you received is just an offer and not a bill or invoice and you are under no obligation to either buy or renew at this time or any time in the future."
The letter is from the Atlantic Publishers Group, LLC, from the beautiful Atlantic town of Niwot, Colorado.
There is nothing wrong with independent magazine publishers soliciting you to buy magazines. Publishers' Clearinghouse has been doing this for years, promising everyone that they "might have already won" millions of dollars. As questionable as those prize solicitations might be, Publishers' Clearinghouse doesn't pretend to be the actual publisher or try to mislead subscribers that that is who they are. They also don't insinuate that you actually owe money on an outstanding bill.
As it turns out the Republican National Committee has crossed that line and is sending out fake bills thatare even more deceptive than the magazine bill above.
According to Rachel Maddow of MSNBC.com, The Republican National Committee, under the signature of, and presumably under the authorization of Republican National Chairman, Reince Priebus, has been sending out letters "PAST DUE" and "NOTICE OF DELINQUENCY". These letters are not just going out to donors and persons who have pledged money.
I can tell you that there are millions of adult elderly people out there who have diminished vision and/or diminished capacity who will pay anything that kind of looks like a bill, and that's why these scams succeed again and again. Some elderly people don't remember what they ordered, and they figure they must have ordered something and forgotten about it. In other cases, the children of these elderly people know that mom or dad spends days at home ordering stuff and they don't want mom or dad's credit to go down the tubes.
if you receive a deceptive fake bill, even if you aren't taken in by it, I urge you to report it to the Federal Trade commission at www.ftc.gov.
"Notice of Continuation" in big bold letters. What else were we to believe? Well, if you look at the bottom, in smaller, thinner red print, you can see "This is an offer from an independent agent, not a bill."
On the back, they repeat that "The offer that you received is just an offer and not a bill or invoice and you are under no obligation to either buy or renew at this time or any time in the future."
The letter is from the Atlantic Publishers Group, LLC, from the beautiful Atlantic town of Niwot, Colorado.
There is nothing wrong with independent magazine publishers soliciting you to buy magazines. Publishers' Clearinghouse has been doing this for years, promising everyone that they "might have already won" millions of dollars. As questionable as those prize solicitations might be, Publishers' Clearinghouse doesn't pretend to be the actual publisher or try to mislead subscribers that that is who they are. They also don't insinuate that you actually owe money on an outstanding bill.
As it turns out the Republican National Committee has crossed that line and is sending out fake bills thatare even more deceptive than the magazine bill above.
According to Rachel Maddow of MSNBC.com, The Republican National Committee, under the signature of, and presumably under the authorization of Republican National Chairman, Reince Priebus, has been sending out letters "PAST DUE" and "NOTICE OF DELINQUENCY". These letters are not just going out to donors and persons who have pledged money.
I can tell you that there are millions of adult elderly people out there who have diminished vision and/or diminished capacity who will pay anything that kind of looks like a bill, and that's why these scams succeed again and again. Some elderly people don't remember what they ordered, and they figure they must have ordered something and forgotten about it. In other cases, the children of these elderly people know that mom or dad spends days at home ordering stuff and they don't want mom or dad's credit to go down the tubes.
if you receive a deceptive fake bill, even if you aren't taken in by it, I urge you to report it to the Federal Trade commission at www.ftc.gov.
Thursday, March 24, 2016
National Collegiate Student Loan Trust can't count to six
I have been hearing more and more stories about the National Collegiate Student Loan Trust (NCSLT) suing student borrowers well after the statute of limitations has expired. In my state, Indiana, the statute of limitations is 6 years from the time the loan goes into default or when the last payment was made, whichever is later. In some states, it is 5 years.
Many people mistakenly believe that there is no statute of limitations for any student loans. Actually, there is no statute of limitations for government-backed student loans; but the ordinary contract statute of limitations applies to private student loans.
In addition problems with the statute of limitations, we are aware of problems with the assignment of some NCSLT loans as well as lack of proof of proper notice to the cosigner in cosigned student loans. In addition, in some cases it may be inappropriate to sue the cosigner in the same place as the chief borrower.
If you are sued by NCSLT, please call our office if you are in Indiana. If you are outside of Indiana, contact the National Association of Consumer Advocates at www.consumeradvocates.org for a referral to an attorney in your area.
Many people mistakenly believe that there is no statute of limitations for any student loans. Actually, there is no statute of limitations for government-backed student loans; but the ordinary contract statute of limitations applies to private student loans.
In addition problems with the statute of limitations, we are aware of problems with the assignment of some NCSLT loans as well as lack of proof of proper notice to the cosigner in cosigned student loans. In addition, in some cases it may be inappropriate to sue the cosigner in the same place as the chief borrower.
If you are sued by NCSLT, please call our office if you are in Indiana. If you are outside of Indiana, contact the National Association of Consumer Advocates at www.consumeradvocates.org for a referral to an attorney in your area.
Are a large number of Ram Promaster Vans Lemons?
The Ram Promaster is the American market version of the Fiat Ducato, a Euro-style van that has been available in Europe for more than 20 years. The Ram version is made in Mexico and has been available since the 2014 model year.
After fielding a telephone call regarding problems with a Ram Promaster van, I did some internet research. Based on what I found, it appears that the Ram Promaster would not be a vehicle that I would consider for my business. If you have a Ram Promaster that has given you trouble, I suggest that you keep good records of the repairs and dates out of service for the possibility of making a lemon law claim.
One good thing is that all or almost all variants of the Promaster have gross vehicle weights under 10,000 lbs. This is the cutoff for protection under the lemon law in Indiana as well as many other states. Most commercial vehicles are heavier and are excluded from lemon law protection.
If you have a vehicle that you think might be a lemon, if you are in Indiana, feel free to contact me. If you are outside of Indiana, get a referral to a lawyer in your area at www.consumeradvocates.org.
After fielding a telephone call regarding problems with a Ram Promaster van, I did some internet research. Based on what I found, it appears that the Ram Promaster would not be a vehicle that I would consider for my business. If you have a Ram Promaster that has given you trouble, I suggest that you keep good records of the repairs and dates out of service for the possibility of making a lemon law claim.
One good thing is that all or almost all variants of the Promaster have gross vehicle weights under 10,000 lbs. This is the cutoff for protection under the lemon law in Indiana as well as many other states. Most commercial vehicles are heavier and are excluded from lemon law protection.
If you have a vehicle that you think might be a lemon, if you are in Indiana, feel free to contact me. If you are outside of Indiana, get a referral to a lawyer in your area at www.consumeradvocates.org.
Saturday, March 19, 2016
Cedar Financial - International Debt Collections and comments for avoiding claims of rental car damage
A friend gave me a letter he received from Cedar Financial, of Calabasas, California. Cedar Financial is a collection agency that specializes in international debt collection. The letter in question was an attempt to collect a little over $300 for a traffic ticket issued in Italy (allegedly, anyway). The letter attempts to comply with the "g" notice Fair debt Collection Practices Act requirements for initial written communications. It notifies the debtor that he has 30 days to dispute the debt, etc.
Just because the notice complies - or attempts to comply- with the FDCPA doesn't mean the account is subject to the FDCPA though. The FDCPA only applies to "consumer debts", and domestic traffic tickets aren't considered to be consumer debts. I've seen no court decisions on foreign debts, but I checked to see what happened when Cedar Financial was sued by other parties, and as far as I could tell, a handful of suits were all dismissed shortly after filed. Now, as far as I know, those suits could have been settled, or they could have been dismissed because they shouldn't have been filed in the first place.
Note that it makes a difference for whom Cedar is collecting. If they are collecting for a foreign government or municipality, I think it is likely that the FDCPA does not apply, but if they are collecting for a rental car company that paid the ticket and is trying to get reimbursed, then the collector likely is subject to the Fair Debt Collection Practices Act. Claims for debts owed to private toll-way operators, EasyPass and the like should be subject to the Fair Debt Collection Practices Act.
I tried to find any indication that they actually sue on any of these accounts, and I was unable to find any. That doesn't mean that they don't sue. It means that I doubt that they will sue. If they do sue, it could be surprisingly complicated to defend, because they could sue you overseas then ask for confirmation of an overseas judgment. This will likely mean any attorney you hire (including me) would have to seriously crack the law books to figure out what the law requires. It looks like they do sometimes report these debts to consumer credit reporting agencies. Here is a case that a consumer filed in US District Court in Florida without an attorney. The other side got the case dismissed. The consumer might have kept the case going if the consumer had filed a dispute with the credit reporting agencies (credit bureaus) prior to filing suit. If Cedar Financial is reporting on your credit reports, call a NACA attorney.
If you get a collection letter from Cedar Financial, I suggest you do the following:
1) Send a dispute letter asking for proof of the debt, asking them who hired them and who owns the debt. Also ask for an itemized accounting for how the amount claimed has been calculated.
2) If they call your cell phone, send them written notice that they do not have permission to call your cell phone. Send it in a form you can prove they received it, either fax with confirmation or certified mail. The purpose of this is to preserve your rights to claim damages for subsequent calls under the Telephone Consumer Privacy Act (TCPA).
If you receive collection calls on your cell phone from Cedar Financial, and you have notified them not to call your cell phone, contact an attorney in your area with the National Association of Consumer Advocates. You can find one in your area at the NACA website at www.consumeradvocates.org.
What will happen if I don't pay Cedar Financial? Well, maybe nothing. They may call you. There's a chance that they'll sue you, but I doubt it. It appears that there is some sort of online database at least in Italy that may make it hard for you to rent a car there again if you have an unpaid ticket. Such a database if applied in the United States would be subject to the Fair Credit Reporting Act, and you would have the right to dispute the information posted on your record, but different countries would have different laws or no laws at all regarding traffic ticket databases. If you are a frequent international traveler, you would have more financial incentive to pay the ticket.
What can I do to prevent claims by rental car companies?
If the claim is for unpaid tickets, including Easypass and other tollways, you should actually pay owed debts. They can be tenacious regarding collections. But if you don't owe the debt, you should send a letter to the collector giving the reasons you don't owe the debt, for example they got your car or license plate number wrong.
Consumers frequently receive claims by rental car companies for damage to rental cars that the consumer never saw. When I rent a car, I always note that dirt on the car makes it hard to determine if there is damage to the car, and I take digital pictures of the car from all angles when I pick it up and when I drop it off. It is easy for memories of a vacation to be spoiled by claims of thousands of dollars worth of damage and loss of use to a vehicle that you rented for a week several months ago. You should always dispute claims for diminished value when they are also claiming the cost of repair to the car's original condition. That is double-collecting for the rental car company. If it is a long-term rental, more damage should be included within the ordinary wear and tear for which the rental car company is already being compensated. If the damages claimed are significant, consider talking to a NACA lawyer before responding. If you are in Indiana or you rented the car in Indiana, I would be happy to help you.
If you want more information on disputing a ticket or fine that you received in Italy, check out this webpage. I can't vouch for its accuracy, but I don't have anything better.
Just because the notice complies - or attempts to comply- with the FDCPA doesn't mean the account is subject to the FDCPA though. The FDCPA only applies to "consumer debts", and domestic traffic tickets aren't considered to be consumer debts. I've seen no court decisions on foreign debts, but I checked to see what happened when Cedar Financial was sued by other parties, and as far as I could tell, a handful of suits were all dismissed shortly after filed. Now, as far as I know, those suits could have been settled, or they could have been dismissed because they shouldn't have been filed in the first place.
Note that it makes a difference for whom Cedar is collecting. If they are collecting for a foreign government or municipality, I think it is likely that the FDCPA does not apply, but if they are collecting for a rental car company that paid the ticket and is trying to get reimbursed, then the collector likely is subject to the Fair Debt Collection Practices Act. Claims for debts owed to private toll-way operators, EasyPass and the like should be subject to the Fair Debt Collection Practices Act.
I tried to find any indication that they actually sue on any of these accounts, and I was unable to find any. That doesn't mean that they don't sue. It means that I doubt that they will sue. If they do sue, it could be surprisingly complicated to defend, because they could sue you overseas then ask for confirmation of an overseas judgment. This will likely mean any attorney you hire (including me) would have to seriously crack the law books to figure out what the law requires. It looks like they do sometimes report these debts to consumer credit reporting agencies. Here is a case that a consumer filed in US District Court in Florida without an attorney. The other side got the case dismissed. The consumer might have kept the case going if the consumer had filed a dispute with the credit reporting agencies (credit bureaus) prior to filing suit. If Cedar Financial is reporting on your credit reports, call a NACA attorney.
If you get a collection letter from Cedar Financial, I suggest you do the following:
1) Send a dispute letter asking for proof of the debt, asking them who hired them and who owns the debt. Also ask for an itemized accounting for how the amount claimed has been calculated.
2) If they call your cell phone, send them written notice that they do not have permission to call your cell phone. Send it in a form you can prove they received it, either fax with confirmation or certified mail. The purpose of this is to preserve your rights to claim damages for subsequent calls under the Telephone Consumer Privacy Act (TCPA).
If you receive collection calls on your cell phone from Cedar Financial, and you have notified them not to call your cell phone, contact an attorney in your area with the National Association of Consumer Advocates. You can find one in your area at the NACA website at www.consumeradvocates.org.
What will happen if I don't pay Cedar Financial? Well, maybe nothing. They may call you. There's a chance that they'll sue you, but I doubt it. It appears that there is some sort of online database at least in Italy that may make it hard for you to rent a car there again if you have an unpaid ticket. Such a database if applied in the United States would be subject to the Fair Credit Reporting Act, and you would have the right to dispute the information posted on your record, but different countries would have different laws or no laws at all regarding traffic ticket databases. If you are a frequent international traveler, you would have more financial incentive to pay the ticket.
What can I do to prevent claims by rental car companies?
If the claim is for unpaid tickets, including Easypass and other tollways, you should actually pay owed debts. They can be tenacious regarding collections. But if you don't owe the debt, you should send a letter to the collector giving the reasons you don't owe the debt, for example they got your car or license plate number wrong.
Consumers frequently receive claims by rental car companies for damage to rental cars that the consumer never saw. When I rent a car, I always note that dirt on the car makes it hard to determine if there is damage to the car, and I take digital pictures of the car from all angles when I pick it up and when I drop it off. It is easy for memories of a vacation to be spoiled by claims of thousands of dollars worth of damage and loss of use to a vehicle that you rented for a week several months ago. You should always dispute claims for diminished value when they are also claiming the cost of repair to the car's original condition. That is double-collecting for the rental car company. If it is a long-term rental, more damage should be included within the ordinary wear and tear for which the rental car company is already being compensated. If the damages claimed are significant, consider talking to a NACA lawyer before responding. If you are in Indiana or you rented the car in Indiana, I would be happy to help you.
If you want more information on disputing a ticket or fine that you received in Italy, check out this webpage. I can't vouch for its accuracy, but I don't have anything better.
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