Comment Submitted by Cheleena Frye

I applaud you for trying to create simplicity for the consumer but unfortunately with your proposed Respa Reform rules you have come up with, it has done the opposite. There are so many mistakes with this proposal, I will hit the hi-lites only. 1) On the proposed GFE: Government Recording and Transfer charges MUST be moved to the charges that can change. Recording fees will ALWAYS vary. Each lender's Deed's of Trust and Riders vary in the number of pages. Plus, if there is often times a Quit Claim Deed, Manufactured Home Title Elimination, Powers of Attorney, etc etc. that is discovered later that is needed. 2) Where does the Closing Agent fall in those 3 catagories of charges. Those too MUST be charges that can change. Because if preparation of any of the said documents above are required, there will be charges for the preparation of those legal documents. 3) No signature on the GFE 4) No signature on the HUD 5) No Section at all for Closing/Settlement or Attorney charges. Our section is completely removed. It MUST be listed on the HUD. 6) VERY CONFUSING, trying to reference said lines to GFE. 7) By creating the script and comparison form which is NOT a closers responsibility to complete, this will create additional time per closing which will incur additional costs to the consumer for our time. Defeating the purpose of trying to save the consumer money. Closers will only be able to do 1 closing in the time we can normally do 3 or 4. Clients will greatly inconvenienced by the length of the closing. They want to sign in less than 1 hour so they can get back to work. 8) Your comparison GFE vs HUD conflicts with our Limited Practice Officers license on legal services we are allowed to provide the client. We are to remain neutral providing no legal advice. 9) 3 day rule for HUD to clients. This is the purpose of a 3 day right of rescission. This will extend clients lock times and again increase the fees to the consumer. Thank you.