Comment Submitted by Angela Hernandez, DHI Mortgage Company

Document ID: HUD-2008-0062-0005
Document Type: Public Submission
Agency: Department Of Housing And Urban Development
Received Date: August 08 2008, at 09:39 AM Eastern Daylight Time
Date Posted: August 8 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: June 9 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: August 8 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806b7b93
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RE: Docket No. FR-5160-P-01 Acceptable Payment History for Late Request for Endorsement of Mortgage For Insurance DHI Mortgage Company respectfully submits comments regarding the Department of Housing and Urban Development’s Proposed Rule on Acceptable Payment History for Late Request for Endorsement of Mortgage for Insurance. The Proposed Rule will require a six month payment history for loans submitted for insurance more than 60 days after closing. Delays other than a late payment may result in an endorsement submission beyond 60 days after closing. For example, delays may be due to incomplete information or missing documentation that is collected after closing. If the proposed rule is passed, the Lender will be faced with uninsured loans for 6 months even if the borrower has made on-time payments but submitted late due to other factors. In addition, investors are tightening guidelines and if lenders are unable to insure government loans in a timely manner, loans may be subject to repurchase. The Proposed Rule may steer companies away from providing FHA financing in a time when product options are limited. Concern for the increase in defaults and claims submitted to FHA may be mitigated by recently passed legislation and revising current FHA guidelines such as requiring pre- and post-funding homebuyer counseling. Homebuyer counseling teaches borrowers the importance of homeownership and financial responsibility. Counseling will benefit the borrower beyond the six months that is proposed in this rule. DHI Mortgage Company would like to thank HUD for the opportunity to comment on the proposed rule. Angela Hernandez Secondary Marketing Operations Manager DHI Mortgage Company

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