After reviewing the loan estimate sample and the closing disclosure sample these are the difficulties I see from the perspective of a Realtor (20 years):
1. The numbers make it plain that the consumer will be pay a lot of interest if they keep their loan for the full term,(in the example - 30 years). However, there is no indication of how much the consumer can save by making additional payments to the principal. All of this information should be given to the consumer as part of the loan estimate, and really don't have a place in the closing disclosure.
2. The 3 day prior to final closing requirement with no option to waive the time period by the buyer is terrible. We live very busy lives. Getting the buyers and the sellers together on the same day is difficult enough. Setting this 3 day period in stone, with no room for agreed upon changes or for all involved agreeing to waive the 3 days is begging for disaster. Many times the sellers are no longer living in the area, or the "seller" is a trustee for an estate - or set of a dozen people who are all part owners/heirs. You give no options and do not take into account anything that doesn't fit your definition of an average closing.
3. In trying to make things more simple and easy to understand, you have expanded the number of line items, turning a 2 page document into a 5 page document. More simple. REALLY?
I invite anyone from your agency who is really interested in hearing how this would work in a small town in the midwest, to come an visit our board of Realtors - East Central Indiana Board of Realtors. To set an appt. call our EO at 765-825-0094.
Thank -you
Comment on CFPB-2012-0028-0406
This is comment on Proposed Rule
Integrated Mortgage Disclosures under Real Estate Settlement Procedure Act (Regulation X) and Truth in Lending Act (Regulation Z)
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