Irwin
Financial Corporation
From: Cline, Brian [mailto:Brian.Cline@ihe.com]
Sent: Friday, April 23, 2004 5:24 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Cc: Kerry Spradlin
Subject: EGRPRA Comment
I chair the Enterprise-wide Compliance Committee of Irwin Finanicial
Corporation, which includes Irwin Mortgage Corporation, Irwin Union
Bank, Irwin Home Equity, and Irwin Commercial Finance. The total
on/off balance sheet assets is a combined $32 billion and we collectively
operate in all 50 states. The Federal Reserve is our primary regulator.
EGRPRA was a topic in the last ECC meeting we had and we applaud
your efforts to reform compliance regulations and would like to provide
you the following feedback.
Reg. B’s
applicability to business credit does not add value in our opinion,
just unecessary
process and expense, particularly
with regards to the provision of denial notices, incomplete application
notices, and processing deadline provisions.
We support Federal pre-emption, especially with regards to privacy
and predatory lending intitiatives to simplify the current regulatory
burden and level the playing field for all financial institutions.
Federally regulated institutions should not have to comply with numerious
requirements while State regulated institutions only have one set
of rules to follow.
Apply consumer compliance regulations and enforcement to our 3rd
parties, mainly brokers and title companies. As Federally regulated
institutions we find that we have to train and clean up basic errors
made by these institutions, usually because of the overly complex
nature of RESPA. Again this is an example of an unlevel playing field
where some institutions are held to higher standards than others
in the same business. Federal regulations and regulators should realize
this and either hold these 3rd parties to the same standard or exempt
us from errors made by the 3rd parties. It is unfair to put us in
the position of regulator for these types of companies.
Thank you for the opportunity to comment.
Brian A. Cline, CRCM, CIA, CRP
VP, Corporate Compliance
Irwin Financial Corporation
12677 Alcosta Blvd., Suite 500
San Ramon, CA
94583
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