Below are summaries changes that the Federal Reserve has proposed. Both proposal are signifant and I believe all realestate professions need to review the proposal and let your comments be known. I can agree that better disclosure of the terms of loans might assist consumers, however the proposal to restrict some payments to Loan Brokers creates an unfair advantage to Banks and Mortgage Banker. In order to understand the advantage to Banks and Mortgage Bankers, consumers need to understand that Banks and Mortgage Bankers earn a Profit or Income when they originate a loan. Some of the income is earned immediately and some is earned each year the loan is on their books. Service Release Premiums or Yield Spread Premiums are both terms that describe the money paid to Mortgage Brokers (and even some Mortgage Bankers) when the loans transfer from one lender to another.
For consumers, they need to understand that Profit is Profit and they want to just consider the cost of identical products. If you want to buy Apples (Money) and the same ones are avaiable from multiple sources, it does not matter if the grower is selling them, sold at a farm market or your local grocery store consumers are smart enought to Shop, Compare and Save. The same would be true with mortgages provided deceptive advertising and marketing practices are not tolerated by lack of enforcement.
Share your opinions by submitting a comment to the Federal Regulators. Also, share your opinions here for others to use in voicing their opions and providing talking points to individual not familar with the importance of these proposed changes.
Regulation Z - Truth in Lending - Home-Equity Lines of Credit (HELOC) [R-1367] Proposed amendments to change the timing, content, and format of the disclosures that creditors provide to consumers about HELOCs at application and throughout the life of such accounts. The proposal would also provide protections related to account suspensions and credit-limit reductions, and reinstatement of accounts Closing date for comments: 11/27/2009
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Regulation Z - Truth in Lending - Closed-end Mortgages [R-1366] Proposed amendments that would revise Closed-end mortgage disclosures to highlight potentially risky features such as adjustable rates, prepayment penalties, and negative amortization and prevent mortgage loan originators from "steering" consumers to more expensive loans Closing date for comments: 11/27/2009
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