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cvm2
211 Posts |
 Posted - 03/25/2008 : 09:03:10 AM
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Legislative and Regulatory Alert from NCAMP
The Federal Reserve has a proposed rule that will ultimately harm your business and curtail the credit markets more than ever before.
The Rule amending Regulation Z (73 Fed. Reg. 1,672 January 9, 2008)
We need your help.
The rule proposes several changes to underwriting and the mortgage industry which will cause harm to your business and to the welfare of your customer.
The Federal Reserve is introducing a new category of loans which will trigger the abolishment of stated and no doc loans under any circumstance.
The Federal Reserve recognizes that all originators receive a form of YSP or SRP but only mortgage broker transactions will require that you disclose before application what your income will be on the loan and this cannot change during the loan application.
The Federal Reserve wants the originator to determine that the borrower has the ability to repay the mortgage they are applying for- for at least 7 years.
The Federal Reserve wants to put triggers in place similar to 1817 to have 3% and 5% caps before the loan would fall into the higher costs loan. This is impossible and the caps must be raised.
The rule is very lengthy and can be found on NCAMP's website along with sample letters.
Please have everyone in your place of business write a letter using one of the sample letters we have on our website as a guide. Do NOT simply copy and put your name on them as mass duplicates are the first to be discarded.
THE FED RULE LETTERS NEED TO BE MAILED AT ONCE!
The cut off for comments is 4/8/2008. Be proactive!! This is the time to take charge of your business!
Letters need to be mailed to:
Jennifer J. Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551
You may also submit comments, identified by Docket No. R-1305, by any of the following methods:
4 Agency Web site: http://www.federalreserve.gov. Follow the instructions for submitting comments at http://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm.
4 Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.
4 E-mail: regs.comments@federalreserve.gov. Include the docket number in the subject line of the message.
4 Fax: (202) 452#65533;3819 or (202) 452#65533;3102.
Thank you for your continued support,
Stacy Kimrey
NCAMP President
* * *
3901 Barrett Drive Suite 202 Raleigh, North Carolina 27609 919.783.0767 919.783.0967 (Fax)
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Scrooge McDuck
7512 Posts |
Posted - 03/25/2008 : 09:05:58 AM
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| dont the lenders already do this? |
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cvm2
211 Posts |
Posted - 03/25/2008 : 09:12:12 AM
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3% cap on fees, in NC we already have the 5% cap
Now we can do stated loans thru banks like Wachovia and Everbank
No more stated loans
that is still alot of my bussiness
FHA is the other have |
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