LAS VEGAS – The American Credit Union Mortgage Associationparticipated in the HUD Roundtable on RESPA Reform held Aug. 25 andfollowed up with a letter to HUD Secretary Alphonso Jackson withits comments that specifically address HUD's Good Faith Estimate.In the association's letter to Jackson, ACUMA Chairman RobertStreet, president/CEO, American First CU, and Treasurer andRegulatory Compliance Committee Chair Steve VanSickler SVP/chieflending officer, Red Rocks FCU, applauded the agency's 2004proposed GFE that begins with “About Your GFE” section. Theyfurther stated that, “It is extremely important that all consumersare made aware of their right to receive a GFE and of what thisdocument is purporting to show them. Any information booklet is aseparate document among many other documents that consumersreceive. The only sure way to make consumers aware is to make surethe “About Your GFE” section survives the final revision andremains the first thing that is seen.” ACUMA recommended thatseveral data points be added to the final page for comparison ofoffers, “to better demonstrate differences between programs.” Amongtheir suggestions are: * Loan Originator compensation should bedisplayed/disclosed on the GFE clearly and prominently to include abreakdown of the exact yield spread premium being earned by alender together with the interest rate quoted. These forms ofcompensation must be clearly visible to a consumer especially whenthey could also be charged an origination fee or discount points orboth and not be receiving any credits. * To eliminate any perceiveddisparative treatment of mortgage brokers, the receipt of anyservicing income whether paid upfront as a servicing releasepremium or annually/monthly as a servicing spread, for thoselenders or bankers who service loans for Fannie Mae or Freddie Mac,should also be disclosed. * Regarding HUD's proposal that anyone inthe mortgage industry should be able to offer a “subpackage,” HUDshould not regulate packaging and allow the marketplace to evolveas long as all benefits from packaging are passed on to theconsumer and there are no Section 8 exemptions given. * Anyopportunity to provide remedies for errors or violations shouldcome with a cooling-off period that would allow the consumer tocomparison shop. Lenders, bankers and brokers should be heldaccountable for any and all violations of RESPA to include apenalty being imposed for failure to deliver required disclosures,to include the GFE, within three days of application.

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