To Whom It May Concern:
In reference to the matter above concerning mortgage loans. I ask that you remove loan officer compensation from the 3% cap in points and fees charges to consumers. Please consider this premise:
1. Points and fees charged to the consumer are already in the 3% cap
2. Loan officer compensation comes from the same points and fees
3. If we add loan officer compensation in the “points and fees cap”, it is double counting the amount
A reasonable solution is to remove loan officer compensation from the 3% cap. I feel that by including loan officer compensation in this proposal, it will be discriminating against the lower loan amounts (and thus the borrowers who can not afford, or do not want to buy homes over the $150,000 threshold). This will hurt Consumers, Realtors, Appraisers, Inspectors and the general economy as a whole.
I urge you to consider excluding the compensation from the 3% cap. Thank you for your consideration.
Comment on CFPB-2013-0002-0001
This is comment on Proposed Rule
Ability to Repay Standards under Truth in Lending Act (Regulation Z)
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