AL65 - Comment - Suzanne McCord

In response to the above referenced 2nd supplemental notice, Wells Fargo Home Mortgage comments are as follows: In regards to the proposed clarifications on Loan Modifications, revision to remove ?or default is imminent? from ?36.4314, paragraph (a)(1), Wells Fargo Home Mortgage is concerned that eliminating our ability to perform a loan modification when default is imminent will have an adverse impact on borrowers in certain situations. Wells Fargo believes in being proactive in preserving a customer?s home ownership. The proposed change will hinder our ability to help borrowers with impending default which is due to a known permanent change in the borrower?s financial situation or because of a scheduled payment increase as a result of an ARM adjustment. Therefore, we propose to leave the option of performing a loan modification when default is imminent in the guide. In regards to the proposed change to paragraph (c) of section ?36.4346 to remove "60 days" and adding, in its place, "30 days', Wells Fargo Home Mortgage asks for the following clarification: Is it the VA?s intent to require Servicers to send the annual escrow statement (in alignment with RESPA) AND the year end statement (?statement of interest paid?) within 30 days after the end of each calendar year although the IRS requires year end statements to be sent no later than January 31st of each year as cited in the Internal Revenue Code sections 6041(d) and 6049(c)(2)(A)? This document provides a second supplemental notice regarding a proposal to amend the Department of Veterans Affairs (VA) Loan Guaranty regulations related to several aspects of the servicing and liquidating of guaranteed housing loans in default, and submission of guaranty claims by loan holders. This notice provides specific information regarding VA's proposal to phase-in implementation of the new electronic reporting requirement and other provisions in the proposed rule published February 18, 2005 (70 FR 8472). In addition, VA is taking this opportunity to address certain comments raised by some members of industry in response to VA's publication of the first supplemental notice to this rulemaking (November 27, 2006 (71 FR 68948)), and to provide further explanation of the ongoing development of VA's computer-based tracking system. VA is reopening the comment period for the limited purpose of accepting public comments concerning the supplemental information provided in this notice.