WASHINGTON-In official comment letters to the Department of Housing and Urban Development (HUD) regarding its recent proposal to simplify the regulations implementing the Real Estate Settlement Procedures Act (RESPA), CUNA and NAFCU charged that the amendments would do just the opposite. "NAFCU supports efforts to simplify and improve the mortgage process," NAFCU President and CEO Fred Becker wrote. "However, NAFCU believes these proposed changes overall will provide additional burdens and interest rate risk for credit unions that outweigh any attempts to simplify the process for borrowers. The proposed rule, if made final, would have a serious and negative impact on the mortgage industry because it would require lenders to guarantee fees from third party service providers and guarantee rates that are market driven." According to CUNA's comment letter from Assistant General Counsel Jeffrey Bloch, the proposed amendments to allow lenders to offer "guaranteed mortgage packages" and rewriting the "good faith estimate" form from one to three pages, will disadvantage smaller credit unions and only serve to confuse borrowers. The guaranteed packages, Bloch wrote, "will likely place small lenders, such as credit unions, at a distinct competitive disadvantage as compared to large financial institutions. Only the large institutions will have the ability to negotiate discount pricing with settlement providers, which can then be passed on to the borrower." NAFCU also suggested the General Accounting Office study the issue.