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NC · jury_instructions

N.C.P.I.—Crim. 220.33

SOLICITATION OF RESIDENTIAL MORTGAGE FRAUD. FELONY.

activein force · 2008-06-01 – presentas-observed

The defendant has been charged with soliciting another to commit

residential mortgage fraud.

For you to find the defendant guilty of this offense, the State must

prove two things beyond a reasonable doubt:

First, that the defendant [enticed] [advised] [incited] [ordered]

[commanded] (name solicitee) to commit residential mortgage fraud.

And Second, that the defendant specifically intended that (name

solicitee) commit residential mortgage fraud. Residential mortgage fraud

occurs when a person, acting for financial gain and with the intent to

[deceive] [defraud], knowingly

[(a) [makes] [attempts to make] any material1 [misstatement]

[misrepresentation] within the mortgage lending process]2 with

intent that a [mortgage lender] [mortgage broker] [borrower] [any

other person] involved in the mortgage lending process rely on it.

[(b) omits material information within the mortgage lending

process.]

[(c) [uses] [facilitates the use of] [attempts to use] [attempts to

facilitate the use of] any material [misstatement]

[misrepresentation] [omission] within the mortgage lending

process] with intent that a [mortgage lender] [mortgage broker]

[borrower] [any other person] involved in the mortgage lending

process rely on it.

[(d) [[receives] [attempts to receive]] [[loan proceeds] [describe

other funds]] in connection with a residential mortgage closing that

the person [knew] [should have known] resulted from [making]

[attempting to make] [using] [facilitating the use of] [attempting

to use] [attempting to facilitate the use of] any material

[misstatement] [misrepresentation] [omission] within the mortgage

lending process with intent that a [mortgage lender] [mortgage

broker] [borrower] [any other person] involved in the mortgage

lending process rely on it.]

If you find from the evidence beyond a reasonable doubt that on or

about the alleged date the defendant [enticed] [advised] [incited]

[ordered] [commanded] (name solicitee) to commit residential mortgage

fraud, specifically intending that (name solicitee) commit residential

mortgage fraud, it would be your duty to return a verdict of guilty. If you

do not so find or have a reasonable doubt as to one or both of these

things, it would be your duty to return a verdict of not guilty.

History

N.C.P.I.—Crim. 220.33 (June 2008). N.C. Gen. Stat. § 14-118.12(a)(4). Prepared by the North Carolina Conference of Superior Court Judges' Committee on Pattern Jury Instructions, assisted by the UNC School of Government; published by the School of Government.

Provenance

Source
sog.unc.edu
Retrieved
2026-09-24
Edition
2026-09-24
Content hash
e76ff60b2f885b282a7dd2309bcc6fd12e9a31a276b55ac12c34f7e1048db55f
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