I think we are in the same boat as you are. We are taking the stance that you will be responsible for making sure they are in compliance, but obviously you want an operating agreement to remind them that they are responsible for complying with everything. It will be up to you to make sure they do. On the HMDA issue, we are going through the first full year of their operation and they were logging everything the old way, and they were used to recording and reporting like a mortgage company (to HUD instead of FDIC), not as a subsidiary of the bank. They were unaware of this until we were doing our CRA audit, hence the need for your compliance people to be involved in the mortgage company's activities, much to your delight.