Massenburg v. Wilshire Credit Corp.

57 Va. Cir. 100, 2001 Va. Cir. LEXIS 520
CourtVirginia Circuit Court
DecidedSeptember 21, 2001
DocketCase No. HK-817
StatusPublished

This text of 57 Va. Cir. 100 (Massenburg v. Wilshire Credit Corp.) is published on Counsel Stack Legal Research, covering Virginia Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Massenburg v. Wilshire Credit Corp., 57 Va. Cir. 100, 2001 Va. Cir. LEXIS 520 (Va. Super. Ct. 2001).

Opinion

By Judge T. j. Markow

This case is before the Court on the Amended Bill of Complaint, the Answer, and Cross-Bill.

Briefly, in January 1997, Sarah Massenburg and Irvin Massenburg and Cityscape Corporation (“Cityscape”) entered into a credit transaction in which the Massenburgs were the borrowers and Cityscape was the lender. In connection with the credit transaction, the Massenburgs executed a promissory note (“the note”) to the order of Cityscape and executed a deed of trust (“the deed”) as a lien on the home at 3125 Enslow Avenue, Richmond, Virginia, to secure the note. Within three years of the credit transaction, CityScape assigned the note to U.S. Bank, National (“National”), which assigned the servicer rights to Wilshire Credit Corporation. Within three years of the credit transaction, Irvin Massenburg died, leaving plaintiff as the sole owner of the home. Plaintiff fell into arrears on the note and National instructed the substitute trustee to foreclose. The substitute trustee advertised the home for foreclosure but during pendency of the non-judicial foreclosure process and within three years of the credit transaction, Massenburg sent notice of rescission to CityScape and Wilshire. The foreclosure sale was enjoined by this Court on the morning of the scheduled sale to maintain the status quo pending resolution of this case.

[101]*101Plaintiff seeks a declaratory judgment that she has rescinded this transaction pursuant to the federal Truth in Lending Act, 15 U.S.C. § 1601 et seq. (“TILA”). The statute requires that plaintiff show that she was a consumer in the credit transaction and that at the time of the transaction the lender underdisclosed the finance charges in an amount exceeding $35 (15 U.S.C. § 1635).

Plaintiffs granddaughter testified without rebuttal that in 1997, when the Massenburgs entered into a credit transaction to refinance an earlier home improvement loan, neither of them was engaged in the operation of a business. Plaintiff testified that both she and Mr. Massenburg were retired at the time of the credit transaction at issue.

This transaction included a $5,975.89 cash-out to the Massenburgs. Defendants argue that there was no stated purpose for the proceeds, that they were not used for home improvement, and, thus, plaintiff was not a consumer for purposes of this transaction.

The majority of the proceeds from the 1997 loan were used to pay off the 1996 loan which the parties stipulate was a home improvement loan. In addition, the loan documents [Plaintiffs ExhibitNumber 9] indicate that the cash out was for “work done on House.” Plaintiff testified that “he [Irvin] never got no [sic] money from them. When he signed the papers, he never got cash.” Plaintiff also testified that the money was intended for a porch enclosure.

In determining whether a transaction is primarily consumer or commercial in nature for purposes of TILA exemption, the court must examine the transaction as a whole and the purpose for which credit was extended. Gombosi v. Carteret Mortgage Corp., 894 F. Supp. 176 (1995). The primary purpose of the loan was refinancing the 1996 home improvement loan, as evidenced by Plaintiffs Exhibit Number 10, in line (d) of Section VII titled Details of Transaction, which shows that $14,500 of the $22,500 borrowed is used to refinance the 1996 loan. These documents are also evidence that the purpose for which credit was extended was to refinance the prior home improvement loan. Thus, the Court finds that the primary purpose of the 1997 loan was for home improvements, a consumer purpose, and plaintiff is a TILA consumer in terms of this transaction.

Though plaintiff has shown that she is a consumer, she must still show that at the time of the credit transaction with CityScape, the lender made an underdisclosure of the finance charges on the 1997 loan in an amount greater than $35. Plaintiff points to several allegedly undisclosed or improperly disclosed figures as evidence of the lender’s underdisclosure, and these fees are listed on Plaintiffs Exhibit Number 6.

[102]*102Ms. Massenburg points first to the $14 Broker Courier Fee as an undisclosed finance fee. However, this fee represents the cost of delivering the borrowers’ credit report, and, pursuant to 15 U.S.C. § 1605(e), fees resulting from procuring borrowers’ credit report are excluded from the disclosure requirement.

Next, plaintiff argues that Connelly and Associates, the closing attorney, is an agent of the creditor and thus the $29 release fee charged by Connelly and Associates is an undisclosed finance fee. This fee represents Connelly’s charge for procuring a release of the 1996 loan that was to be refinanced by the 1997 loan. (Connelly could not have earned this fee until after the loan closed.) This was not a fee charged by or required by the lender but was a request of the lender in the loan settlement instrument. As such, this fee does not represent a finance charge as defined in 15 U.S.C. § 1605.

The allegation with regard to the $45 courier fee paid to Connelly and Associates is that it represents an inaccurate disclosure of the actual courier fee paid. However, Mr. Connelly testified that his firm benefits from a rebate program offered by FedEx, the courier involved. A rebate is a return of some part of the amount paid, meaning Connelly and Associates paid the $45 courier fee first and then received the $8 or $9 back. Thus the amount that was reported paid to the courier is accurate, it merely does not reflect the rebate and plaintiff offered no evidence in proof of her right to that rebate. Thus, the courier fee was accurately reflected in the disbursements. Connelly could not have disclosed the actual charge as the amount of the rebate was determined by the total amount of business Connelly did with the courier over a specified period of time, including a future time.

Finally, with regard to TILA violations, Ms. Massenburg directs the Court’s attention to the $16 recording fee that was to be paid to the clerk of the court for release ofthe prior deed of trust. Plaintiff claims and defendant’s witness admits that these moneys were never paid to the clerk of the court and that, in fact, the clerk’s release fee had already been satisfied out of previous funds. These funds were refunded to the Massenburgs upon Mr. Connelly’s recognition of the error and furthermore, fees such as this, to be paid to public officials, are excludable pursuant to § 1605(e).

The Court finds that Ms. Massenburg is a consumer in a credit transaction. However, since all of the fees allegedly undisclosed or improperly disclosed were excludable pursuant to TILA or simply did not meet the definition of a finance charge, plaintiff has failed to prove underdisclosure in an amount in excess of $35 and thus has not satisfied the statutory requirements for proving a violation of the federal Truth-in-Lending Act.

[103]*103Ms. Massenburg has also asked the Court for an alteration in the timing of tender. Because the Court finds that plaintiff has not proved a violation of TILA, it need not reach this argument.

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57 Va. Cir. 100, 2001 Va. Cir. LEXIS 520, Counsel Stack Legal Research, https://law.counselstack.com/opinion/massenburg-v-wilshire-credit-corp-vacc-2001.