Dossier summary

Business-Purpose Exemption Limits

The distinction between disclosure exemptions and broader anti-steering or UDAAP review.

This page summarizes public records, third-party reporting, and disputed complaint materials. It does not state that unresolved allegations are true or that any person or entity violated the law unless a cited regulator or court record says so.

Professional record context

People named in the record

Public professional identifiers are provided for source review. Personal contact details are intentionally omitted.

Public professional profile

Vicki Smith

Role
New Home Sales Consultant
Organization
PulteGroup
License number:
Not established by current cited sources.

Pulte Homes Tennessee is listed in a separate public listing record as professional context only.

Vicki Smith's LinkedIn profile (opens in a new tab)

Public professional profile

Mackenzie Curtis

Role
Divisional Builder Manager
Organization
Acrisure Mortgage
NMLS ID
NMLS ID #471956

The submitted complaint identifies Mackenzie Curtis as a Mutual of Omaha Mortgage Regional Vice President, Builder Division, in August 2025. Her current official profile lists Acrisure Mortgage, so this site does not imply an ongoing Mutual affiliation.

Mackenzie Curtis's current official profile (opens in a new tab)

Public company context

Mutual of Omaha Mortgage

Public professional profile

Tony Fragale

Branch Manager, Vice President of Mortgage Lending

NMLS ID #76480

The cited official profile establishes public professional context only; it does not identify a connection to the Dupont complaint.

Official public profile (opens in a new tab)

Mutual's position

Mutual relies on business-purpose classification and signed affidavits to support its position that certain consumer-disclosure rules do not apply.

Mutual states the loans were originated and closed in compliance with applicable law.

Rebuttal position

The rebuttal agrees the loans were investment-purpose but argues that business-purpose classification does not end anti-steering or UDAAP review.

The rebuttal also argues that signed affidavits do not answer whether the borrower was misled about product availability or deprived of meaningful comparison.

Review focus

This site should avoid deciding the legal issue. The page should identify the competing arguments and point readers to the records needed for legal review.

Related resources

Sources