CLAREMONT
SAVINGS BANK
From:
Richard Mailloux [mailto:rmailloux@claremontsavings.com]
Sent: Monday, April 19, 2004 3:16 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: subject=EGRPRA
Gentlemen;
Claremont Savings
Bank is a mid-size Mutual Savings Bank located in the
South Western part of New Hampshire. At present we do not have a full time
compliance officer, and we are currently monitoring compliance by using four
of our Senior Officers Although this process has served us well for a
number of years, needless to say, this method is very expensive.
As you know,
regulations pertaining to lending, include Reg Z, Fair
Lending, Community Re-Investment Act, ECOA, Fair Credit Reporting Act, Fair
Housing, Home Mortgage Disclosure Act, Reg O, RESPA and I'm sure I've missed
one or two.
To insure our
compliance with these regulations, we also have to allow
staff time for compliance exams. All this to protect a consumer who are at
their wits end with government parenting that adds additional cost to their
need to borrow money.
Our primary
competition is from Mortgage Companies. Our question is who
examines them?. The State their licensed in? If so, I'm sure the quality
of the compliance exam is not equal to that of FDIC.
It is not only
the burden of complying with lending regulations that is
making lending more complicated than it should be. We are also required to
gather data for third parties such as the IRS who have no connection with
loan at all. These include filings for such things as interest paid on
loans, amounts disbursed to contractors on construction loans, attorney fees
that are collected at closing, and provide information of property sales.
It seems that we are being called on to provide information to IRS for those
who may not be declaring all of their income. This of course is paid by the
consumer in one form or another.
One suggestion
we would have is to create one regulation entitled "Anti
Discrimination Act" to included any and all possibilities for
discrimination. This could possibility eliminate ECOA, Fair Lending, Fair
Housing. Also, in conjunction with this recommendation would be to create a
simple language law. It is important to put something in front of the
consumer that they stand a reasonable chance of understanding. We insist on
protecting them, but take away the tool for them to protect themselves by
putting document in front of them that they don't fully comprehend. One
time,,,, have a legislator try to explain Reg Z to a consumer that has just
purchased their first home with an ARM product. (Please invite me to that
closing, I'd love to watch)
Sincerely;
R Mailloux
Claremont Savings Bank
rmailloux@claremontsavings.com
Vice President/Senior Loan Officer
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