Comment Submitted by Carolyn Smith, Comstock Mortgage

Document ID: HUD-2010-0097-0003
Document Type: Public Submission
Agency: Department Of Housing And Urban Development
Received Date: October 14 2010, at 12:00 AM Eastern Daylight Time
Date Posted: October 15 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: October 8 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: December 7 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b6f0c8
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This is comment on Proposed Rule

FR–5156–P–01 Federal Housing Administration Single Family Lender Insurance Process: Eligibility, Indemnification, and Termination

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We see loans that the FHA Total Scorecard approves that should not be approved, and we as a responsible Mortgagee do not approve those loans. Extremely high ratios, bad credit with no compensating factors. No savings of their own, and on and on. Until the FHA Total Scorecard is fixed, or completely thrown out I don't see how HUD can reasonably enforce this. Your own system is assessing risk contrary to your direction here.

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Comment Submitted by Jeff Brader
Public Submission Posted: 10/14/2010 ID: HUD-2010-0097-0002