Comment focusing on several reasons why Department of Housing and Urban Development (HUD) should exclude escrowing monthly Homeowner Associations (HOA) dues submitted by Joan V. Timm, Residential Mortgage Group, Incorporated (RMG)

Below are some reason why I think HUD should exclude escrowing monthly HOA dues from the final rule:1) Unlike insurance escrows (which are disbursed annually), or property tax escrows (which would be disbursed twice a year), I believe maintaining escrows on monthly HOA dues will prove to be very problematic. The funds would need to be disbursed immediately on a monthly basis to an infinite number of small companies that will not be set up (like a large insurance company or a County) for receipt of those funds. 2) The nature of HOA dues is completely unlike collecting 1/12th of a homeowner's annual insurance premium or 1/12th of their annual property taxes. Everything that is budgeted by an Association is included in the monthly HOA dues: paying for lawncare, garbage removal, management and/or accountants fee, fees for audits and tax preparation, premiums for the blanket HOA insurance, premiums for workman's comp insurance, on-going projects like replacement of decks/roofs/siding, miscellaneous expenditures, and funds for reserves. For those reasons no Association is going to want their dues routed through a mortgage company. 3) The time frame for collecting and disbursing are too short. Most mortgages access their late fees on the 16th of the month, while many Associations access late fees around the 10th of the month. Who is going to be responsible for a late fee accessed on a payment that the mortgage company receives on the 9th, but can't reasonably disburse back to the HOA before the 10th? 4) But most importantly, escrowing for the monthly HOA dues will not eliminate the underlying problem that is causing the homeowner to not be able to make their HOA payments. Thank you in advance for considering my comments.Respectfully SubmittedJoan V. TimmVice President / Underwriting ServicesRMG, Residential Mortgage Group, Inc.6465 Wayzata Blvd., Suite 720St. Louis Park, MN 55426joni@rmgmn.com Resdiential Mortgage Group, Incorporated (RMG) This comment is included entirely within this index record. There is no PDF.