The
Peoples Bank & Trust Company
From:
Tia Breedlove [mailto:tiab@thepeopleplace.com]
Sent: Monday, April 19, 2004 6:20 PM
To: Comments; regs.comments@federalreserve.gov; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
From: Tia Breedlove
Date: April 19, 2004
To: Comments
Subject: Reduce Regulatory Burden from Lending-Related Consumer Protection
Rules
Thank you for
giving us the opportunity to express our views on some burdensome
consumer protection rules. Our comments are as follows:
• National
Flood Insurance Reform Act of 1994 requires that all lenders provide
notification to the borrower, “Notice of Special Flood Hazard
and Availability of Federal Disaster Relief Assistance”,
when the building securing the loan is located in a Special Flood
Hazard Area (SFHA). This notice is required on loan originations
as well as refinances. At the time of the refinance when the borrower
is aware that the property is located in a SFHA because they have
an active flood policy in effect, giving the notice and giving
the notice a reasonable time (10 days prior to closing) is burdensome.
If all insurance
is through FEMA and the same cost to the customer, why can’t
we force place insurance on a note that requires flood insurance?
The cost to the borrower should be the same.
• RESPA
requires the Servicing Disclosure be given to the customer at the
time of application if in person and within 3 days if by phone.
Since these disclosures originally pertained to home purchase loans
but now are required on all residential mortgage transactions,
why can’t the Servicing disclosure be given within the 3
day period as is the Good Faith and the Truth-in-Lending.
• Reg B
new guidelines effective April 15, 2004 require confirmation of
a joint application yet the Fannie Mae and Freddie Mac applications
do not required any more than joint signatures. If both borrowers
sign the application, their signatures should confirm the request
for a joint application. Initialing the request for a joint application
at the top of the application and signing the application seems
to be double confirmation and burdensome.
Thank you for
allowing me to express my concerns of these particular regulation
issues.
Sincerely,
Tia Breedlove,
Asst. V.P.
Compliance/CRA Officer
The Peoples Bank & Trust Company
Tupelo, MS
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