WELCH STATE
BANK
Re: EGRPRA Review
of Consumer Protection Lending Related Rules
Dear Sir or Madam:
Ever since I
entered the workforce I have dealt with government regulations.
The first six years were with the U.S. Army and the last ten have
been banking regulations. I remember thinking to myself that I
wouldn’t have to deal with all the bureaucratic, unreasonable,
government regulations after I got out of the military. Little
did I know how wrong I was. Most of our concern used to be with
safety and soundness. Now we are ten times more concerned with
all the regulations we have to follow.
Truth in Lending
(Federal Reserve Regulation Z)
Right of Rescission.
A person comes to me and we talk about refinancing their house.
I give them an application that they fill out and return to me.
I give them preliminary disclosures for them to review. We obtain
an appraisal and title insurance. Then we sit down and go through
the documents that include a final truth in lending statement and
final disclosures. Then I have to tell them they must wait three
business days for right of rescission to expire. I wish you could
see the look on their faces. They aren’t happy about it and
they think it is stupid to have to wait. It’s as if this
rule from the government is telling them “you aren’t
smart enough to handle your financial affairs so we put this in
place to protect you.” How many people have actually used
the right of rescission on a loan they applied for? I think this
rule has been setup to protect the few instead of the many.
Flood Insurance.
It needs to be
simplified. Especially for mobile homes that don’t include
real estate. We were told by the regulators that the definition
of permanently affixed was utilities were hooked to the mobile
home. We interpreted permanently affixed as wired down or set on
a foundation. This caused us to almost receive a fine. Please make
this regulation more streamlined and simplified.
Equal Credit
Opportunity Act (Federal Reserve Regulation B). If the person doesn’t
want to give out the information that they are male or female and
what race they are, why should we have to try and guess what they
are and give you the information anyway?
I am a small
community bank in Northeast Oklahoma. I keep spending more time
trying to comply and keep up with your regulations. You just keep
adding to the regulatory burden. You never reduce it. Please do
something about it! You are driving the small banks out of business.
Sincerely,
James A. Stoner
President
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