Comment on CFPB-2012-0033-0019

Document ID: CFPB-2012-0033-0026
Document Type: Public Submission
Agency: Consumer Financial Protection Bureau
Received Date: October 02 2012, at 12:00 AM Eastern Daylight Time
Date Posted: October 2 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 17 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: October 9 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-816h-tti3
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I am requesting you exempt small community banks from all aspects of this proposal. If a bank services its own mortgage loans, services less than 10,000 loans, is $10 Billion dollars or less in total assets, or some combination thereof it should be exempt from these requirements. As a small community bank it is necessary, and our belief, that it is beneficial to both us and our borrowers to provide them sufficient information about their loan payments, to process those payments as soon as practical, and exhaust all possibilities to help them when they cannot make payments as originally agreed. To place these requirements on banks such as ours is to require us to develop new formal systems for things we are already doing. The establishment of those systems is particularly burdensome for small institutions. Large institutions and servicers already have the systems and manpower to more easily put in place these requirements at a cost much less proportionate to the smaller institutions. Thank you.

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