Comment from Kevin McNichol, Reverse Mortgage Consultant

Document ID: FFIEC-2009-0001-0003
Document Type: Public Submission
Agency: Federal Financial Institutions Examination Council
Received Date: December 17 2009, at 12:00 AM Eastern Standard Time
Date Posted: December 30 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: December 16 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: February 16 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80a6cc37
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I have been a Reverse Mortgage Consultant for 7 years. The industry has been making great strides to accomplish many of the goals that will result from your guidance and many changes have been implemented. A few major lenders have been ahead of the curve in terms of those changes and implemented policies and internal controls to combat many of the issues raised. One questionable change that I have not seen raised as possible negative is that the requirement that either the counseling session or the application for the reverse mortgage be done face to face was eliminated a few years ago. In my mind this opens the reversee mortgage proccess to more potential actual or percieved abuse than would exist otherwise. I think this should be a topic of your discussions.

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Comment from Kevin McNichol, Reverse Mortgage Consultant
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