Comment regarding situations that may be exceptions to the property flipping rule submitted by Jane Stentz, Union Bank and Trust Company

eRegulationsAgency : HOUSING AND URBAN DEVELOPMENT DEPARTMENT Title : Prohibition of Property Flipping in HUDs Single Family Mortgage Insurance Programs; Additional Exceptions to Time Restriction on Sales Subject Category : Mortgage and loan insurance programs: Single family mortgage insurance-- Property flipping prohibition and sales time restriction exemptions Docket ID : CFR Citation : 24 CFR 203 Published : December 23, 2004 Comments Due : February 22, 2005 Phase : RULES Your comment has been sent. To verify that this agency has received your comment, please contact the agency directly. If you wish to retain a copy of your comment, print out a copy of this document for your files. Please note your REGULATIONS.GOV number. Regulations.gov #: EREG - 1 Submitted Dec 30, 2004 Author : Ms. Jane Stentz Organization : UNION BANK AND TRUST COMPANY Mailing Address : 6801 S 27TH ST LINCOLN, NE 68512 US Attached Files : Comment : Regarding the exception for situations of inheritance; what about situations whereby the property may have been transferred from two owners into the name of one of those owners (i.e., divorce, joint ownership to sole ownership, etc.)? I know of an example where two non-married idividuals jointly owned a property whereby one of them assumed the mortgage into their own name, thus the other party signed the entire property over to that person via a quit claim deed. Would this not be a circumstance valid for exception (like that of an inheritance)? For example, in this situation since these individuals were not married the state required revenue on the deed equal to one half the current market value to be paid upon filing of the quit claim deed and transfer of title from both individuals names into one of their names alone. There was not truly a sale that occured here although it would appear of record that one person sold their one half interest to the other, which is how it would show up in the appraisal. The way the property flipping rule is now and the way in which it is intended to be changed will still force this situation to fall under the property flipping rule and I'm of the opinion that this should not necessarily be true. Also, Fannie Mae appears to be changing their guidelines in an attempt to monitor and control property flipping. Might it not be valid to give further consideration to including Fannie Mae and Freddie Mac as part of the exception for foreclosure situations? I realize that these GSE's are not regulated in the same way as federal agencies like RD, VA, etc., however they do appear to be following line with HUD regarding property flipping. Union Bank and Trust Company