PUBLIC SUBMISSION | As of: November 21, 2009 Tracking No. 803fc799 Comments Due: May 13, 2008 |
Docket: HUD-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
Comment On: HUD-2008-0028-0001
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
Document: HUD-2008-0028-0010
Comment Submitted by Christy Brady Janssen, The Law Offices of Christy Brady Janssen
As a solo practitioner, I rely heavily on my paralegal for closings. It is not the
closing agent's responsibility to explain every single lender-imposed fee to the
borrower. This should be handled by the lender at either the commitment letter
stage or the good faith estimate stage. This proposed rule is 1) confusing and
unclear (not to mention lengthy); 2) does not promote shopping by the consumer;
3) it is ill timed given the current conditions in the housing market; and 4) the
requirement of a closing script required to be read by the closer to the customers
at closing raises a host of problems, not the least of which is the unauthorized
practice of law. In short, this bill is a disaster.