Your department continues to roll out excessive regulations without thinking through the unintended consequences. Because of what you have done already regarding Loan Officers compensation, you have virtually put all mortgage brokers out of business and thousands of people formerly in the mortgage industry have departed for other lines of work. As a result of your regulations, Loan Officer's income has been slashed. That resulted in an exodus from the field. What you didn't think through is now, due to the shortage of "qualified" LO's, it is taking 3 months or longer to get loans closed at Bank of America, Wells Fargo, Chase, Citi, Compass, etc. I know as I personally recently did a mortgage at B of A and it took over 3 months!
Lenders are having a hard time getting purchases closed by the contract date thereby affecting the realtor's relationship with the lender. The buyer is then mad at both the realtor and lender and often is left with significant additional cost because they have moved out of their home thinking they were closing on a new one. When they don't close on time they must put their belongings in storage and stay in a hotel or weekly rental, incurring much added expense. And, this is all your fault because you keep trying to "fix' everything with new regulations and all you are doing is making things worse. Wake up!! Stop screwing with LO compensation and stop trying to fix something that is not broken!
Comment on CFPB-2012-0037-0049
This is comment on Proposed Rule
Truth in Lending Act (Regulation Z); Loan Originator Compensation
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