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HUDRulemakingHUD-2008-0028

FR-5180-P-01 Real Estate Settlement Procedures Act (RESPA): Proposed Rule To Simplify and Improve the Process of Obtaining Mortgages and Reduce Consumer Settlement Costs

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Mortgage Bankers Association filings
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Mortgage Bankers Association filed 3 comments on this docket between Jun 13, 2008 and Jul 8, 2008. 588 other organizations filed here. The comment window closed 6620d ago.

What Mortgage Bankers Association filed (3)

Jul 8, 2008· Comment Submitted by Jonathan Kempner, Mortgage Bankers Association· HUD-2008-0028-4198

Filed on regulations.gov — full text not in the inline record.

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Jun 23, 2008· Comment Submitted by Anthony Armstorng, Mortgage Bankers Association of Maine· HUD-2008-0028-3701

TO: US Department of Housing and Urban Development RE: Comment on Proposed RESPA Rule: Docket No FR-5180-P-01 I am writing on behalf of the Mortgage bankrs Association of Maine to express our opposition to the proposed revised RESPA Rule for the following reasons: 1. The proposed rule does not address many of the issues that are at the heart of the recent problems in the mortgage banking industry because it does not provide information to borrowers in a concise form. The four page good faith estimate disclosure document, added closing requirements and related rules associated with the good faith estimate are still too confusing for borrowers. 2. The proposed rule will add to costs for consumers in the long run because it will drive honest, competitive lenders out business and reduce competition. This is because it will require smaller mortgage brokers and mortgage bankers to disclose "yield spread premium" information which is not required to be disclosed by larger mortgage banks, banks and credit unions. These larger lenders could be required to disclose similar information reflecting their average yield on loans sold, but have not been required to do so. This confusing and unfair playing filed clearly is destructive of business competition. 3. The inflexible rules related to "locking in" to a rate early in the process will make it very difficult for lenders to be flexible with borrowers who have provided incomplete information early in the application process. We think the revised rule should be reviewed again by HUD through a public hearing process so that it can be improved and so that the obvious bias in favor of "large lenders" can be addressed. Please keep in mind that some the most egregious actions against consumers in recent years have been undertaken by large lenders who close loans with their own funds and in their own name and would not be impacted by the proposed rules related to "yield spread premiums." Sincerely Anthony A. Armstrong Chair Mortgage Bankers Association of Maine 5 Milk Street, Second Floor Portland, ME 04101

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Jun 13, 2008· Comment Submitted by William Kooper, Mortgage Bankers Association· HUD-2008-0028-2304

Attached are the official comments of the Mortgage Bankers Association

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Abstract

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Co-filers (588)

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