Comment Submitted by Kevin Marconi, United Fidelity Funding Corporation

This proposed rule would make it unfair for a small or midsized lender. In order to comply with the proposed statute properly a lender would have to create an entire division whose sole function would be to qualify and recertify brokers for entrance into the FHA loan program. Even after this department was created, in order for this to be done successfully; very specific and detailed guidance would have to be given to each lender. Along with the guidance cost based tools should be provided. Would neighborhood watch still record the compare ratios of the individual brokers? This is a valuable tool and a way for the lenders to communicate to see previous performance of inidvidual brokers down to the branch level. How would this tool still be available if FHA no longer regulated brokers directly.? How would individual lenders communicate the portfolio performance to other lenders. Without this it may make an atmosphere where a broker will burn a lender, get deactivated and then move on to another lender. Even worse how can we as a lender ensure that our approval criteria are not too lax or not too stringent in comparison to other lenders nationwide. It is obvious that this brings more questions than anything and I am very skeptical about this proposed set of rules. Kevin Marconi kmarconi@uffmortgage.com