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No, that consent order does not state that future foreclosures must be verified by an independent third party. It does state that past foreclosures for 2009 and 2010 will be reviewed by a third party to be sure that the bank complied with the law. The consent order also states that the bank must have certain policies in place regarding the use of third parties for future foreclosures. As a practical matter, the bank does use third parties for all foreclosures simply because it has no choice. For example, the bank must hire attorneys to handle the foreclosures. The attorneys are not bank employees, but outside firms.

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