“To whom it may concern: The QM rule, and the stringent parameters it will introduce into mortgage lending, will immediately prevent many home buyers from entering into property ownership. Furthermore the changes to RESPA and TILA will eventually penalize the borrowers in penalties for untimely closings. It has been shown to date that the majority of the laws put in place to supposedly protect the consumer are directly affecting them, and costing them more money to obtain financing. HVCC is a perfect example of sky-rocketing costs passed on to the consumer, as well as the comp reform laws that prevent Loan Officers or their companies from assisting them with closing fees as has been possible in the past.
What becomes obvious from reading many of the proposed changes is that those directly responsible for dictating them are not fluent in the industry, and have little to no knowledge of the actual consequences. More reform just means more cost to the consumer, more delays in closing, and little to assist them with the transaction as a whole.
I urge you to consider opinion and information from those of us in the trenches every day trying to do our absolute best for our clients, before finalizing something that will ultimately become a detriment, rather than a positive solution.
Comment on CFPB-2013-0018-0001
This is comment on Proposed Rule
2013 Mortgage Rules under the Equal Credit Opportunity Act, Real Estate Settlement Procedures Act, and the Truth in Lending Act
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