From:
Jay Randall [mailto:jtr@CommunityBankIowa.com]
Sent: Thursday, March 25, 2004 8:42 AM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
From: Jay T. Randall, President, Community Bank, Dunlap, IA
A $63,000,000.00 rural bank with offices in 7 small communities.
FLOOD
Most appraisals have disclosure of the Flood Status, I feel if the appraisal
makes note of the information, why do we need a separate form? Requiring a
standard form is a redundancy of work and adds additional costs, either directly
by the bank or indirectly through the appraisal.
ECOA
It is my understanding that the requirement for notation of “evidence
of intent” for individual versus joint applications is a consumer protection
effort. The guidance for non-consumer loans (non-incorporated commercial and
agricultural loans) will cause some problems.
•
I feel that a borrower’s signature on a promissory note should be enough “evidence
of intent”, particularly for loans which are not subject to “Truth
in Lending”.
HMDA
The purpose for tracking refinancing of agricultural or commercial loans that
may be secured by the applicant’s residence is excessive.
• Simplify Spread Reporting, expanding reporting of spread into tiers of
rates is excessively burdensome
• Use only necessary data fields
• Increase Asset Size for data collection
• Current discussions to expand collection items should be dropped until
after completion of this EGRPRA review of the regulation.
Truth in Lending (TIL)
While a nice tool for examiners to determine whether or not as financial institutions
we are abusing our consumers and for consumers to comparison shop; the bottom
line to the consumer is still whether or not the financial institution will
make the loan, not what the APR, finance charge or amount financed is disclosed.
• I feel the determination thresholds for accuracy of the APR are too narrow.
• The requirement for multiple disclosures of the sale of credit insurance
and whether the bank may keep a portion of the commission is unnecessary.
RIGHT OF RECISSION
In twenty-seven (27) years of banking, I have never had a customer that has
rescinded a transaction. While I understand the three (3) day period, it feels
to be an extra burden on the borrower.
• Give customers that right to waive rescission at closing, or
• Repeal the entire requirement.
HOEPA
Simplify Spread Reporting, use same requirement as HMDA.
CRA
While CRA gives financial institutions a fair review as to how they are serving
their communities and what they are doing to meet the needs. This regulation
needs substantial simplification. In the past twenty-two (22) years, our
financial institution has had only ONE (1) request from a consumer to look
at our public information file. The work that is involved for compliance
to the regulation, maintain the policy, board review of the policy, file
maintenance, notices and files in all offices, is not cost effective.
• Repeal the Regulation, or
• Grant more exemptions and
• Raise the Asset Total for small institutions
RESPA
How many times must we show the customer, basically the same information? Good
Faith Estimates, Itemization of Amount Financed, HUD 1 or 1A. While there are
differences in the forms and they come about through different regulations,
isn’t there some way to consolidate.
PRIVACY NOTICES
• Initial Notice at account opening should be sufficient or
• When policy changes.
• Eliminate requirement to send annually.
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