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commission of 6 percent of the sale price of each unit
sold.
Another affiliate, Continental Appraisal Group, Inc.
(CAG), appraised the residential properties purchased by
EPIC partnerships. The appraisals were made either by a
member of the CAG staff or by an outside appraiser and
reviewed by a staff appraiser. CAG also appraised
properties for unrelated lenders. Another company, EPIC
Securities, Inc., wholesaled the limited partnership
interests in EPIC partnerships and received a percentage
of the capital contributions as a commission. Finally,
in October 1983, EPIC or one of its affiliates acquired
Community Savings & Loan, a Maryland-chartered savings
and loan association.
Private Mortgage Insurance
While EMI originated the loans at issue, each of the
loans was insured by a private mortgage insurance company
for 25 percent of the first loss amount. Tricor Mortgage
Insurance Co. and Republic Mortgage Insurance Co. (RMIC)
issued mortgage insurance covering the first mortgage loans
at issue in the instant cases. In addition, EPIC dealt
with other mortgage insurance companies, including Mortgage
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