PUBLIC SUBMISSION | As of: November 21, 2009 Tracking No. 80407d38 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-2008-0028-0023
Comment Submitted by Johnny Walker, Century 21 Schutjer Realty
Interesting proposals. As a Realtor and mobile notary public signing agent, I
would welcome any additional efforts at more transparency. However, it was my
experience over the last three years that not only did consumers not understand
what they were signing, most weren't interested in the details. Many were merely
interested in getting their purchases closed or their refinance transactions funded.
These changes mean nothing if ALL lenders, including banks and credit unions,
are not included. In my experience, all kinds of fees are hidden regardless of
which institution is originating the loan. It would not be a fair business practice to
punish third party mortgage originators, while financial institutions such as
Countrywide and Wachovia (formerly the World Saings division) offer products that
put the consumer at risk the day the sign the loan.
Other suggestions I would make would include prohibiting negative amortization
loans for anyone with a FICO score below 780, or altogether for primary
residences. Stated income loans are often referred to as "liar's loans" and for
good reason. I would eliminate stated income entirely. Had the industry
practiced good underwriting principles all along, we wouldn't have the housing and
liquidity crisis that we are currently enduring.
Again, the bank loan officers are just as guilty of putting consumers in loans they
couldn't afford the day the signed the documents as third party mortgage
orignators, so I would hope that any future RESPA changes would be universally
applied.