FDIC Federal Register Citations

Campbell & Fetter Bank


From: Doug Targgart [mailto:DTarggart@campbellfetterbank.com]
Sent: Monday, April 19, 2004 9:37 AM
To: Comments
Subject: EGRPRA burden reduction comment

Dear Sirs,

Here is a couple of items we feel need to be addressed:

HOEPA - under the fees test.
A loan being reported as a HOEPA because of credit life and disability insurance does not make sense. Banks have the customers sign the Federal Insurance Disclosure saying that they cannot make credit life or disability insurance a condition of a loan. Also, if the loan gets paid-off early the customer is entitled to a rebate. The fees test itself seems to be a test of income the bank is receiving. Our bank does not earn the full premium listed on a loan. We only earn a percentage of the premium, but are forced to list the full premium under the HOEPA fees test. More importantly, it is the customer's decision to be insured not the banks. The bank can set the customers rate, documentation, application fee, etc.

Flood Survey Requirement
A flood survey is always required when there is a mortgage and structure involved. We question why there needs to be a flood survey done when we only place a mortgage for the customer's tax purposes. For example, we do an auto loan and say the vehicle is sufficient collateral, but file a mortgage for tax purposes only. We feel a flood survey does not need to be required because we will hold the title to the vehicle and require the customer to carry auto insurance.

Thank you,

Doug Targgart
Campbell & Fetter Bank
P.O. Box 231
126 S Orchard St
Kendallville, IN 46755