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The declaration states her qualifications as a licensed California real estate broker and mortgage professional, explains her independent analyst/journalist role, and describes her involvement and observations regarding seller-funded down-payment assistance programs. It addresses HUD guidelines on counting down-payment monies for FHA insurance, the use of intermediaries and “non-profit” charities, and cites HUD and GAO findings on increased FHA risk.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/declaration-of-krista-railey-declaration-in-support-of-defendants-opposition-to-plaintiffs-motions-for-a-temporary-restraining-order-and-preliminary-injunction/279868/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/declaration-of-krista-railey-declaration-in-support-of-defendants-opposition-to-plaintiffs-motions-for-a-temporary-restraining-order-and-preliminary-injunction/279868.png","ImageObject",442,249,{"name":88,"@type":89},"Emma Mercer","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-27","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":40},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"Who is Krista Railey and why is her declaration relevant?","Question",{"text":108,"@type":109},"Krista Railey states she is a licensed California real estate broker and mortgage professional with 20 years of industry experience and an independent analyst/journalist. Her background is presented to support the credibility of her statements in the case.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What are “seller-funded down-payment assistance programs” in the declaration?",{"text":113,"@type":109},"The declaration describes DAPs as programs that provide money so buyers can make down payments, including forms that are funded by sellers. It explains the FHA-related context for the required 3% down payment.",{"name":115,"@type":106,"acceptedAnswer":116},"How does the declaration address HUD rules and the use of intermediary charities?",{"text":117,"@type":109},"It explains that HUD guidelines generally prohibit lenders from counting seller-given monies toward the buyer’s 3% down payment. It further describes how some DAPs use non-profit “charities” as intermediaries to circumvent the guideline, and cites risk concerns raised by HUD and the GAO.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},279868,1790213395,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":40,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":8,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":139,"read_time":79},962084925502,"https://ap-avatar.wpscdn.com/davatar_6f874abed73319feea01a86fa6f0fab8","UNITED STATES DISTRICT COURT  \nFOR THE DISTRICT OF MARYLAND  \nGLOBAL DIRECT SALES, LLC, PENOBSCOT )  \nINDIAN NATION, CHRISTOPHER RUSSELL )  \nand RYAN HILL, ) Case No.: 8:08-cv-02468  \n)  \nPlaintiffs, )  \n)  \n-v- )  \n)  \nAARON KROWNE, individually and d/b/a THE )  \nMORTGAGE LENDER IMPLOD-O-METER and )  \nML-IMPLODE.COM, KROWNE CONCEPTS, )  \nINC., IMPLODE-EXPLODE HEAVY ) Assigned:  \nINDUSTRIES, INC., JUSTIN OWINGS, KRISTA ) Hon. Deborah K. Chasanow RAILEY, STREAMLINE MARKETING, INC. and )  \nLORENA LEGGETT, )  \n)  \nDefendants. )  \n__________________________________________ )  \nDECLARATION OF KRISTA RAILEY IN SUPPORT OF DEFENDANTS’OPPOSITION TO PLAINTIFFS’ MOTIONS FOR A TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION  \nI, Krista Railey, declare as follows:  \n1. I am over 18 years of age and competent to testify to the matters below.  \n2. I make the following statements based on my personal knowledge. If called to testify under oath in a court of law as to the matters set out herein, I could and would do so truthfully.  \nMy background  \n3. I am a licensed California real estate broker (California Real Estate broker license number 00978970) and mortgage professional, with 20 years in the mortgage and real  \nestate industry, including loan processing, underwriting, quality control, and agency representation.  \n4. I am an independent analyst and journalist, whose column, the “FHA Mortgage Whistle Blower,” is hosted on the Mortgage Implode-O-Meter Website. I am not an employee of Aaron Krowne, Justin Owings, or the Mortgage Implode-O-Meter and do not receive story assignments or requests for the Mortgage Implode-O-Meter either in this case or generally.  \n5. I have been employed by Streamline Marketing Inc. since June 2000, but the Whistle Blower Blog is not owned, operated, or sponsored by Streamline Marketing Inc. I write my articles on my own time from my home in Vista, California. To protect the privacy of my residence, however, I use the Streamline Marketing business address for correspondence.  \nPlaintiffs’ Involvement In Seller-Funded Down-Payment Assistance Programs  \n6. Plaintiffs Russell and Hill are part of the seller-funded “down-payment assistance program”(DAP) industry, first with The AmeriDream, Inc. company and now with Global Direct Sales, Ltd. and the Penobscot Indian Nation.  \n7. DAPs are programs that provide money to buyers so they can make downpayments on homes. Many DAPs are seller-funded. In their “purest” form, a seller-funded DAP means that the seller of a home either directly or indirectly “gives” the buyer the 3% downpayments that is required for a loan to be insured by the FHA.  \n8. HUD guidelines to mortgage lenders prohibit those lenders from counting toward the buyer’s 3% down-payment any monies that the seller gives to the buyer. According to HUD guidelines, the only down-payment grants that may count toward the 3% down-payment are those coming from either tax-exempt charities, governmental agencies, public entities, or  \nemployers. Attached hereto as Exhibit A is the HUD manual “Mortgage Credit Analysis for Mortgage Insurance on One-to Four Family Properties,” Chapter 2, Section 2-10 (c) [4155.1 Rev 5], which shows what entities may provide gifts to buyers that can count toward the 3% downpayment requirement.  \n9. Many seller-funded DAPs are established as non-profit charities in order to circumvent this HUD guideline. Such “charities” act as a third-party intermediary between a seller who is funding the down-payment and his buyer. Sellers typically raise the selling price to make up for the funding they have indirectly provided to the buyers.  \n10. According to reports by HUD and the U.S. Government Accountability Office, seller-funded DAPs have led to a substantial risk to FHA insurance funds due to increased delinquency rates, and have resulted in an increase in the effective cost of homeownership. Attached hereto as Exhibit B is a true and correct copy of the relevant excerpts ofthe March 200","cbCaiiIid91cOBLm","https://ap.wps.com/l/cbCaiiIid91cOBLm","pdf",43817,"English","# Declaration of Krista Railey\n## Background\n## Plaintiffs’ Involvement In Seller-Funded Down-Payment Assistance Programs","[{\"question\":\"Who is Krista Railey and why is her declaration relevant?\",\"answer\":\"Krista Railey states she is a licensed California real estate broker and mortgage professional with 20 years of industry experience and an independent analyst/journalist. Her background is presented to support the credibility of her statements in the case.\"},{\"question\":\"What are “seller-funded down-payment assistance programs” in the declaration?\",\"answer\":\"The declaration describes DAPs as programs that provide money so buyers can make down payments, including forms that are funded by sellers. It explains the FHA-related context for the required 3% down payment.\"},{\"question\":\"How does the declaration address HUD rules and the use of intermediary charities?\",\"answer\":\"It explains that HUD guidelines generally prohibit lenders from counting seller-given monies toward the buyer’s 3% down payment. It further describes how some DAPs use non-profit “charities” as intermediaries to circumvent the guideline, and cites risk concerns raised by HUD and the GAO.\"}]","Declaration of Krista Railey - Declaration in Support of Defendants’ Opposition to Plaintiffs’ Motions for a Temporary Restraining Order and Preliminary Injunction | PDF",1789528581]