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FDIC Federal Register Citations

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


 

 

 
Last Updated 05/13/2004 regs@fdic.gov

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