PUBLIC SUBMISSION | As of: November 20, 2009 Tracking No. 803fdefb 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-2008-0028-0012
Comment Submitted by James Dewey
I am an attorney-title agent in a small town. While I can appreciate a need to
have a better disclosure of broker fees and some way to link the good faith
estimate to the actual closing costs, most of the proposed changes will neither
simplify nor improve the process of obtaining mortgages. I expect a major
conflict between the proposed fee agreements with our Louisiana bar association
rules. I also believe that the idea that recording fees are fixed is not
realistic. I don't know what has to be recorded until I receive the loan
documents and don't get that until after I have supplied my estimate of
recording costs, which is normally done at the time I issue a commitment, long
before I know what is going to be include in the mortgage documents. I
actually try to compare the GFE with the closing costs, and normally find errors
in the insurance estimate, the appraisal fee, and the per diem. I also
sometimes find errors in lender fees, for which I can't see much of an excuse.
Rather than change the HUD form, come up with a new form to compare the GFE with
the numbers on the final HUD. Of course, most of my customers are hopelessly
confused over costs, APR, good faith estimates, and related disclosures so
whatever changes are made won't really help them a great deal.