Comment Submitted by Werner Jasinski, Security Atlantic Mortgage Co., Inc

We appreciate the opportunity to comment on the subject proposed rule. Please accept our comments below: 1) The footnote to the words ".....paragraphs (A) through (C)......." located in the last paragraph of page 32632 states that 'On September 5, 2007, HUD announced FHASecure, an initiative that allows families with strong credit histories.....'. To our knowledge, neither Mortgagee Letter 2007-11 nor 2008-13 required that families have "strong" credit histories. 2) With respect to 203.255(b)(14), please clarify the meaning of "submits a loan for endorsement more than 60 days after closing.....". For example, a lender submits a loan for endorsement on or about the 50th day after closing, but the Homeownership Center issues a Notice of Rejection (NOR). The lender submits, on the 68th day after closing, the additional documentation or clarification which will permit the loan to be insured. In this example, must the lender submit, in addition to the documents/info specified by the NOR, a certification that no payment has been more than 30 days late? Again, thank you for the opportunity to review and provide comments.