Comment Submitted by Leo Dunn, Bay Banc Mortgage

FR-5356 Continuation of Reform will result in the demise of 1/3 of what is remaining in the mortgage industry. It will lead to further increases in unemployment, commercial vacancies and personal bankruptcies. The effect will not be limited to mortgage companies alone but will have a corresponding effect on all settlement providers and third party vendors. It will however strengthen major banks over time as they are ensured a virtual industry monopoly, but you will not obtain any sense of that from reading this proposal. What the 1/3 of us fully understands but is not written in this proposal is the devastating impact of the one –two punch of ML-01-10 “Continuation of Reform” with the new RESPA disclosures requirements. One rule usher you on to the reservation, the next one rations the amount of food and water. Most Federal officials who will read that statement will find it utterly preposterous, but then again they have never operated a business, created a job or made a payroll. The combination of these two laws will effectively place a mortgage broker at a disadvantage to the Federal bank competitor and eventually force him to recognize that they will not be able to compete thus the ensuing layoffs and commercial vacancies. But we have all been here before and if there is one thing we know it is that we have learned nothing from history. Federal Housing policies were the center piece of this demise and much like iin in 1936 Federal policies will limit the recovery through the growth engine of small business