Comment on AN78-Interim Final Rule-Wood, Michael

Our primary concern with this Interim Final Rule regarding changes to the VA's existing loan modification guidelines is the language "as of the date the Modification Agreement is executed". The FHLMC Weekly PMMS rate is subject to change weekly. Often times, it takes more than a week to draft, perform quality review, and deliver loan modification documents to the homeowners. In the case of this ruling, we are also dependent on the homeowner quickly, if not immediately, executing the documents upon receipt even though doing so in some cases will present a logistical challenge to them. We foresee the potential for servicer rework and growing frustration for the homeowner. EverHome Mortgage would appreciate VA's reconsideration for this particular part of its ruling and ask that the language be amended to read "as of the date the Modification Agreement is approved". This will afford us the ample time necessary in each Loan Modification case to ensure a more sound transaction process. Thank you for your time and consideration in this matter.