Comment on CFPB-2013-0010-0001

In regard to verifying the borrower's income and qualifications for their job: 1.) The consumer's past employment record; Our current process of verifying previous employment by obtaining complete tax returns for the most recent two years, with all attachments, 30 days of paycheck stubs (computer generated & with no corrections/alterations), completing a phone verification, and pulling a 4506T Income Statement from the IRS makes good sense. Wish these requirements had always been in place and hope they always will be! (ii) the consumer's qualification for the position; This could result in a large number law suits by borrowers, and/or their employers, should a lender make a determination that the borrower is not qualified for their current position (and therefore deny their loan). If the lender verifies directly with the borrower's employer, via phone certification, and with tax returns/paystubs; then how can we really tell the borrower (and their employer) that they are not qualified for the job they currently hold? What if the employer decides to use our determination as a reason to fire their employee? Additionally, we are not proficient in every profession such that we can decide who is and isn't qualified for their position. How can we reasonably make such a determination? (iii) the consumer's previous training and education; Please look at my previous comments on determining a borrower's qualifications for their position. (iv) the employer's confirmation of continued employment. I've been a Mortgage Banker for approximately 32 years. It has been rare to see an employer that is willing to complete the section of the verification of employment concerning the probability of continued employment. Layoffs can occur at any time and through no fault of the borrower or their employer. So how can we reasonably verify that employment will continue for any borrower, much less for up to three years after the loan has closed?