PUBLIC SUBMISSION | As of: November 21, 2009 Tracking No. 80408603 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-2008-0028-0025
Comment Submitted by Steve Shepherd
One of the goals listed in the proposal says that the new regulation would
facilitate shopping. The proposed regulations claim that with the inclusion of six
pieces of information you would have a GFE application. Those six items include:
Name, SSN, property address, gross monthly income, borrowers estimate of the
house price, and amount sought for the mortgage loan.
Most mortgage companies provide prequalification information to prospective
applicants upon request. This is very common for most prospective applicants.
Thus, most shopping is done without a "property address". If regulators want
mortgagers to complete GFEs within reasonable estimates to try to facilitate
shopping, why would the "property address" be needed for the GFE application?
Usually when a property is identified, the borrower needs a loan and is captive to
the mortgager.
The fundemental problem with the GFE is that the GFE is not filled out in good
faith, and not in a way that allows for the shopping of settlement services. Thus, if
a property address is needed, the new regulations have not increased the
likelihood that a GFE will be provided to a prospective applicant.