First United Bank & Trust
May 13, 2004
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW.,
Washington, DC 20429
RE: EGRPRA burden
reduction – Consumer Protection – Lending
Related Rules
Dear Mr. Feldman,
We appreciate the efforts to reduce regulatory burden on the financial
services industry and thank you for providing the opportunity to
voice our opinion. First United Bank & Trust takes this request
for comment seriously and has evaluated our comments in the following
summary.
•
12CFR 226 (Reg Z) - Truth in Lending – 3 day Right of Rescission.
This regulation can be considered an inconvenience to the borrower.
The borrower generally has ample time from the date of application
to the date of closing to review the transaction and their subsequent
financial position. It is an unnecessary burden on the lender and
borrower alike. We urge the deletion of this requirement.
•
RESPA, HUD (Reg X) – Servicing Transfer disclosure – This
disclosure should be required only for lenders who actually sell
loan servicing. Why should a lender have to disclose the fact that
they do not participate in this practice? Customers do not care to
know if the lender sells servicing, but do care to have one less
disclosure to sign.
•
Flood Hazard Insurance – The requirements of this regulation
are extremely burdensome on financial institutions. Why place this
burden on financial institutions and not the insurance industry?
The process for flood map amendment or revision is tedious for the
consumer. Why should a borrower be required to purchase flood insurance
for a structure that is not considered for support of loan repayment?
•
HMDA – Reg C – HOEPA, Rate Spread and Preapproval – The
new data requirements under HMDA have added many work hours to an
already laborious task of HMDA data reporting. This regulation should
be evaluated to determine if it produces meaningful results for today.
Please accept these comments to aid in reducing the regulatory burdens.
Your guidance and consideration are appreciated.
Sincerely,
First United Bank & Trust
Jeanette L. Wampler
Compliance Officer
Greg W. Hinebaugh
Director of Consumer Lending
Beverly A. Sines
Credit Administrator
Kathy J. Knotts
Consumer Mortgage Operations Manager
Diane Armentrout
Regional Sales Executive
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