Free Response to Motion - District Court of Colorado - Colorado

Case 1:03-cv-02485-MSK-PAC

Document 345-3

Filed 02/16/2006

Page 1 of 21

EXHIBIT B

Case 1:03-cv-02485-MSK-PAC

Document 345-3

Filed 02/16/2006

Page 2 of 21

Robert P. Accetta 1/17/2006
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

Page 1

1

Volume I, Pages 1-126
Exhibits: 1-7

2 3
4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

5
6

7 --------------------------8 Camille Melonakis-Kurz,
9 Individually and on behalf of

14 Defendant 15 ----------------------------16
17 18

vs. 13 Heartland Horne Finance, Inc.
12

11 Plaintiff

10 other similarly situated employees
Docket No. 03-MK-2485

VIDEOTAPED DEPOSITION OF ROBERT P. ACCETTA
Tuesday, January 17, 2006, 9:41 a.m.

19

20
21 22 23
24

50 Congress Street, Suite 415
Boston, Massachusetts

25

-------Reporter:

Joan M. Cassidy, RPR, CRR-------

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1

A.

Try and figure out maybe what their current

2 payments were at the interest rate that might have

3 been showing and perhaps look at a couple of
4 scenarios or try and present a couple of scenarios

5 before you call them in terms of how much you might
6 be able to save them per month or what the cash flow

7 might be and so forth under the, you know, current

8 interest rate.
9

Q.

How did you corne up wi th the different

10 scenarios?
11
12

A.
Q.

I'm sorry?
Well, when you would prep the lead and you

13 would corne up wi th ideas for presenting scenarios to

14 the potential clients
15
A.
Q.

16
18

Uh-huh. how would you corne up wi th those
Again, you were just guessing at what their

17 scenarios?
A.

19 payment might be now and what kind of payment you

20 could gi ve them wi th the current rate that we had on
21 our rate sheets that day and see what the difference
22 in the payment might be, excuse me, staying wi th a

23 30-year or perhaps reducing the term or things of

24 that sort.
25
Q. And these scenarios that you would develop,

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1 would you do that on your own?
2

A.

Yes, usually, yeah. After I got used to,

3 you know, reading the rate sheet and that kind of

4 stuff, yes.
5

Q.

About how long did it take before you fel t

6 comfortable to do it on your own?
7

A.

I would say about two months, a hundred

8 percen t on my own.
9

Q.

After you had prepared for this ini tial

10 phone call and developed your scenarios, then what

11 would you do?
12
A.
Q.

Call the customer.

13 15

And what would you talk about wi th the
Pretty much say that, you know, I've been

14 customer?
A.

16 given information that you were looking to refinance
17 and maybe throwing out some open-ended questions of

18 "What are you trying to do," "I see your current
19 rate is," "Is that correct," "What are your goals,"

20 try and get some questions out of them.
21 23 25
Q. And did you have a goal in this first phone
A.
Trying to make a sale.

22 call?
I'm sorry, let
24 me -- I understood the goal was -- let me back that
up a little bit.
I guess the ini tial goal was to

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1

Q.

Okay.

If during this initial phone call

2 the client expressed an interest in moving forward
3 wi th you and wi th Heartland, then what would you do?
4

A.

Get their Social Securi ty number and run a

5 credi t report.
6
7

Q.

And then what would you do?
Review the credi t report and then, again,

A.

8 go back to developing some scenarios for them.

Q. When you would review the credi t report, 10 what were you looking for?
9

11

A.

C red its cor e , p a ym en t his tor i e s, b a 1 an c e s

12 on the mortgages or mortgage, credit card debt or 13 other debt out there that they either might or might
14 not have considered consolidating.
15
Q.

And why would you look at those particular

16 categories on the credit report?
17

A.

It's all part of the mortgage -- developing

18 a mortgage for someone in terms of credit score, 19 debts, outstanding debts, and so forth, and also
20 trying to hopefully corne up with a best scenario and

21 maybe in places where the customer hadn't even

22 thought of consolidating other debt. 23 And analyzing this credi t report, was tha t Q.
24 something tha t you did on your own?
25
A.

Eventually, yes.
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1

Q.

How long was it before you were able to do

2 tha t on your own?
3

A.

Yeah, I would say a hundred percent,

4 probably about two months.
5

Q.

After you analyzed the credi t report, you

6 stated that you would then develop scenarios?
7
8

A.
Q.

Yes.
Would you describe that process for me,

9 please.
10
11 12

A.
Q.

Which process?
What kind of scenarios would you develop?
It really depended upon the credi t report,

A.

13

qui te honestly.

I mean, if they had an extremely

14 poor credit report, you had to kind of look at it
15 and think about what's called subprime loans for
1 6 the m , so met h i n g to kin d 0 f - - a san i mm e d i ate

17

Band-Aid to get them over their hump.

If they had a

18 decent credit score, then you might be looking at
19 "well, if you just refinance your mortgage, your

20 payment will be this, but if you refinance these
21 other debts, then your payment will be that, and
22 this will save you so much more a month."
23 25
Q.

So is it fair to say that the scenarios you

24 developed depended upon each individual client?
A.

Yes.
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1 document as it speaks for itself.
2

Q.

Okay.

You will see, Mr. Accetta, at May

3 2003 there is a loan that the fees percentage

4 charged i s .66 percen t; do you see that?
5 6
7
8

A.
Q.

Uh-huh, I do.
Al so for September 2002 --

A.
Q.

Uh-huh.
in the last column there's 4.61 percent;

9 do you see that?
10 11 13
14
A.
Q.
I do.

Tha tis the kind of range to -- which I was

12 referring to in my prior question.
A.
Q.

Sure.
Is that range based on the fact that the

15 origination fee changed per loan?
16
17 18

A.
Q.

No.
Why would there be a range like that?

A.

Well, I can tell you on the May 8 one, May

19 of -- that you're referring to, that was one of

20 the -- again, it was a no-cost refinance. And as

21 you can see, her name or that person's that
22 customer's name appears earlier in the document
23
or I think it should appear earlier.

(Witness

24 reviews document.) Yeah, she's in October of 2002,

25 when I did the finance for them the ini tial -- the
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1

first time.

The rate went down, so I was able to

2 contact this customer and say, Listen, I can lower
3 your ra te by whatever percen tage we lowered it, and

4 it won't cost you anything.
5

Q.

Were there other times where you would

6 contact a customer after something like that had

7 happened?
8

A.
Q.

Sure.
If we could just stay with this document

9

10 for a few more minutes.
11
12
A.
Q.

Uh-huh.
Under the column "Lender" -- and I will

13 state it for the record -- there are various lenders
14

listed under "Lender" other than HMB.

There is

15 Interfirst, NCB, MTG NET, National City, Aegis,
16
18

A-e-g-i-s, World and New Century.

Do you recall

17 using those lenders that I just listed?
A.
Q.
I do.

19

Did you decide to use those lenders?

20
22
24

A.

When you say I decided, I'm not sure what

21 you mean by that.
Q.

Why would there be lenders other than HMB

23 tha t you would close a loan through?
A.

Sometimes it could be a loan that Heartland

25 couldn't do.
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1

Q.

Okay. And if there was a loan that

Page 25

2 Heartland couldn't do, what would happen? What

3 would you do?
4

A.

I would then send it out to other lenders

5 to see if they could do it.
6

Q.

Did you decide to send -- what other

7 lenders to send it to?
8

A.

If it was turned down by Heartland, yes, or

9

maybe wi th some help through the manager.

Ini tially

10 certainly he knew better than I did.
11
Q.

So do I understand you correctly that

12 initially you would ask your manager for a
1 3 r e co mm end at ion 0 f 0 the r 1 end e r s ?

14

A. Yes.
Q. And then eventually you would understand
A.

15
17 18

16 what other lenders you might take the loan to?
Yes.
Does that --

Q. And it looks like to me approximately 27 or
so times you went outside of HMB.

19

20 21
22

A.
Q.

If that's
meet wi th your recollection?

A.

Whatever it adds up to, I mean I

I mean,

23 I'll agree with what's here, but that's all -- I

24 mean, I can only -- I'm going to say yes because

25 that's what presented here.

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1

A.

The loan programs tha t tha t particular

2 lender was doing, kind of what their niche was in

3 the market.
4

Q.

Would you use that new information as a

5 loan officer at Heartland?
6 7
8

A.
Q.

Sure.
How would that new information be helpful?

A.

Well, I know the program I went through

9 with New Century was just pretty much just -- a lot
10 of their information was just on selling techniques

11 as was some of the other lenders would do stuff with

12 us.
13
14
Q.

What do you mean by "selling techniques"?
Just ways to overcome maybe obj ections, a

A.

15 way to, you know, talk with a particular client,
16 ways to be able to move forward.

Q. And what information did you learn at the 18 World Savings seminar that was helpful?
17

19

A. A very unique loan program.

20
22
24

Q. According to our records, there are about

21 61 or so loans that you closed while you were at

Heartland. Does that fit your recollection of the 23 number of loans you closed while you were there?
A.
Q.

To my recollection.

25

And it also appears from our records that

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1 you closed loans in a couple other states other than

2 Massachusetts?
3
4

A.
Q.

Yes.
New Hampshire and Connecticut?

5
6

A.
Q.

Yes.
Did the states have any different rules or

7 regulations regarding the loans that were closed?
8

A.

What do you mean -- could you clarify what

9 you mean by regulations?
10 12
Q.

Regulations governing the loan closing

11 process.
MS. NOVAK:

You mean state laws? Is

13 that what you are just referring to?
14
Q.

State or federal laws.

15

A.

Well, the federal would have been federal,

16 you know, for every state.
17

Q.

Uh-huh.
I know Connecticut required us to be Those were really the maJor

18

A.

19 21 23
24

individually licensed.

20 things then.
Q.

Were you individually licensed in

22 Connecticut?
A.
Q.

Yes, I was.

When did you acquire your license for

25 Connecticut?
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1

A.

It was either when Heartland started doing

2 loans in Connecticut or when Connecticut required us
3

4 first.
Q.

to be licensed.

I don't remember which kind of carne

5

So at some point during your period of

6 employmen t wi th Heartland?
7
8

A.
Q.

Yes.
Did you have to take a test to become

9 licensed?
10
11

A.
Q.

No.
Going back to the process we were

12 describing earlier, after the title and the
13 appraisal were ordered and you handled locking in

14 rates and working out origination fees, then what
15 would happen?
16
17

A. As I said, the application was mailed to

the client.

I would usually ask them to call me

18 when they got it if they had any questions and then

19 review with the customer what documents they had

20 returned and wai t until the application carne back.
21
23

Q. And did you answer any questions that the
A.

22 clients might have about those documents?
As best as I was able to, and initially I

24 needed help on that.
25
Q.

At what point did you no longer need any

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1 help?
2

A.

I would say it took probably a couple of

3 months.
4

Q.

Is it fair to say that there is a learning

5 curve as a loan officer at Heartland?
6

A.

There is a learning curve as a loan

7 officer, period.
8

Q.

*After you talked with the client again and

9 reviewed the documents wi th them and answered any

10 questions that they might have, then what would

11 happen?
12

A.

I'm sorry, again? Repeat the question.
MS. RAYMOND:

13

Would you mind reading it

14 back.
15 *

(Question read.)

16

A. Again, wait for the application to be

17 returned, wai t for the ti tle to corne in, and wai t

18 for the appraisal to be completed.
19

Q. Then what would happen?

A. When the application carne back, I would 21 review the income information that was sent in, make
20

22 sure it was accurate, and then give it to the

23 processor.
24
Q.

And then what would happen?

25

A.

The package was then sent to underwri ting.
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1

Q. After the package was sent to underwri ting,
A.
We would wai t for the review of

2 then wha t happened?
3

4 underwri ting, and any condi tions were then sent back

5 to us to fulfill at that point.
6
7

Q. And what do you mean by "conditions"?

A. Anything that the underwriter might need

8 further clarification with or be -- maybe initial

9 in corn eve r i f i cat ion 0 rem p 1 0 ym en t ve r i f i cat ion,

10 maybe the appraisal hadn't corne in yet or the ti tle

11 hadn't corne in yet or there were questions on one of 12 those two.
13

I f the underwri ter did have condi tions, 14 what would you do in those situations?
Q.

15

A.

It would depend what they were.

If it was,

16 again, some clarification that I needed from the
1 7 client, I would call them and you'd get them to send

18 in that information.
19

Q. And if it had to do with the appraiser
A.
Q.

20 you'd get him -21
22
Contact the appraiser, right.

So is it fair to say that if there were

23 conditions, you would take care of coordinating
2 4 resolving the condi tions?

25

A.

Yes.
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1

Q.

What was the next step after that?
After all the condi tions -- you were just

2

A.

3 kind of wai ting to get all the condi tions cleared

4 and once everything was cleared, you would get what

5 they refer to as clear to close, and then the

6 closing would be scheduled.
7
8

Q.

Did you schedule the closing?

A.

I honestly don't remember how it was done
I think I may have called the

9

at that time.

10 customer to find out some available dates and times,
11 and then it would be coordinated through the ti tle

12 company, is I think the way it was done.
13 15
Q.

For local closings did you attend the

14 closings?

A. I tried to.
Q. Why would you try to attend them?
A. Meet the client, establish some rapport,
I f the closings were nonlocal, did you

16
17

18 make sure everything went smoothly.
19
Q.

20 attend those?
21
22
24
A.
Q.

No.
Were you present by phone during nonlocal

23 closings?
A.

I would give them

if I was not in the

25 office, I would give them my cell phone.

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1

Q. And why would you gi ve them your cell
A. Again, just to tell them in case any
And to whom did you provide your cell phone

2 phone?
3

4 questions carne up, to call me.
5

Q.

6 number?
7
8

A. Usually, the attorney and the customer.

Q. When you say "attorney," whose attorney are
A.

9 you tal king abou t?
10
12

The title company attorney or the notary.

11 Notaries were used in New Hampshire.
Q.

Did a client ever call you with questions

13 during a closing?
14

A.

I would probably say yes.

I mean, I can't

15

recollect a specific situation.

I would even tell

16 them to call me after the closing to make sure
17 everything went okay, or I would at least follow up
18 wi th them after the closing if I hadn't heard from

19 them.
20 22
Q.

Did the attorney or notary ever call you

21 with questions during the closing?
A.
Q.

Yes.
What kinds of questions would the attorneys

23 25

24 have?
A.

I mean, when we started closing loans in

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1 New Hampshire, we found that the notary really did

2 not have a lot of information, I guess is probably
3 the best way to put it, about the mortgage process.

4 They were just there to really make sure the person 5 was the person who they said they were and to stamp
6 the forms as opposed to explaining any questions
7 that might have corne up at the closing.
8

Q.

Okay.

So in those situations you would

10 A. Yes.
11
Q.

9 answer the questions that the client had?
While you were a senior loan officer at

12 Heartland, were your duties different from when you

13 were a loan officer at Heartland?
14

A.
Q.

A little.

15

And how's that?
The expectation was that, you know, you

16

A.

17 were to be a leader, that when the manager wasn't 18 there, you were the next person in charge.
19

Q. As a senior loan officer, did you ever
A.
Q.

20 train any loan officers while you were at Heartland?
21
22
I helped train some.

Who did you help train?

23

A.

Specific names or -- what are you looking

24 for?
25
Q.

I'm sorry, that was an unfair question.

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1 New Hampshire, we found that the notary really did

2 not have a lot of information, I guess is probably
3 the best way to put it, about the mortgage process.

4 They were just there to really make sure the person

5 was the person who they said they were and to stamp 6 the forms as opposed to explaining any questions
7 that might have corne up at the closing.
8

Q.

Okay.

So in those situations you would

10 A. Yes.

9 answer the questions that the client had?

11 Q. While you were a senior loan officer at
12 Heartland, were your duties different from when you

13 were a loan officer at Heartland?
14 15

A. A little.
Q. And how's that? A. The expectation was that, you know, you

16

1 7 were to be a leader, that when the manager wasn't
18 there, you were the next per son in charge.
19

Q. As a senior loan officer, did you ever
A.
Q.

20 train any loan officers while you were at Heartland?
21
22
I helped train some.

Who did you help train?

23

A.

Specific names or -- what are you looking

24 for?
25
Q.

I'm sorry, that was an unfair question.

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1

A.
A.
Q.

Okay.
You need to clarify that.

2 3
4

Q. Who were you helping to train them?

Okay. You said that you would help train 5 the loan officers? 6 A. Yes.
7
8

Q. Who else was training them?

A. The manager.
Q. SO you would assist the manager in training
A.
Q.

9

10 the loan officers?
11 12
14

Yes.
Did the loan officers ever ask you

13 questions wi thout going to the manager first?
A. Yes.
Q. And what kinds of questions would they have
A.

15
17

16 in those instances?
In some areas it might be just "what do I

18 do next" in terms of the process, or "how do I do
19 the next thing" to -- again, maybe just helping them

20 look at scenarios as well.
21
Q.

As a senior loan officer, did you ever

22 recommend scenarios to your manager?
23
24
A.
Q.

I'm not sure if you mean for myself or --

Did the managers -- did the manager, while

25 you were at Heartland, also close loans?
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1 close through an outside lender, were any of those

2 not permitted to close by the manager?
3

A.

You mean and then turned back into

4 Heartland deal s?
5 6
7

Q.

(Nodding. )

A.
Q.

I hone s tly don't remember.
Why do you think it was that if you were

8 using an outside lender, you were supposed to, as 9 you understood that, have a manager look that loan

10 over?
11
MS. NOVAK:

Objection, calls for

12 speculation.
13
14

A.
Q.

I don't even understand your question.

Okay.

Did you say earlier that if a loan

15 was going to close with a lender other than HMB, a

16 manager was supposed to look that loan over?
17

A.
Q.

Yes.
Why was the manager supposed to look the

18

19 loan over?
20 21
A.
To see if it could go through Heartland.

Q. And if it couldn't going through Heartland,

22 did the manager permi t you to continue along wi th

23 using the outside lender?
24
A.
Q.

Yes.
You mentioned earlier being left in charge

25

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Case 1:03-cv-02485-MSK-PAC

Document 345-3

Filed 02/16/2006

Page 21 of 21

Robert P. Accetta 1/17/2006
Camille Melonakis-Kurz, et al. v. Heartland Home Finance, Inc.

1

2 3
4

often did that happen? A. When he was on -- the manage r was on vacation, you know, once or twice in there; or, you know, he might have been called out to go out to the
How

of the office.

Page 118

5

main office in, like, maybe Chicago or

so it was

6 sporadic.
7

Q. About how long would the manager be gone
A.

8 and leave you in charge of the office?
9

It could be anywheres from a day to maybe,

10 you know, say if he was on vacation, for a week or

11 so.
12
Q.

While the manager was away from the office,

13 did you have hiring and firing authori ty?
14

A.
Q.

No.
Did you have authori ty to wri te up any loan

15

16 officers?
17 18

A.
Q.

I'm not sure if I did or didn't.

Did both Nassef and Mike Tuomala ask you to

19 oversee the office while they were out?
20 21
23
24

A.
Q.

Mike did.
So Mike asked you to oversee it.

Did

22 Nassef ever ask you to oversee the office?
A.
Q.

I don't remember.

Going back to the conversations that you

25 heard through the walls, were there any other
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