From: Ken Mathis
Sent: Friday, March 05, 2004 4:14 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
RE: Truth in Lending, Right of Rescission, Part 226.23
After 20 years of mortgage lending, I have not had one applicant
rescind a mortgage loan. A good average for closing a real estate
loan from application to closing date is about 30 days. If the
applicant has not changed his/her mind within that 30 days, they
are not likely to in the next 3 days. If the intention for the
rescission period is to allow them time to review closing documents
for such items as APR, principal borrowed, payment amount, etc.,
then why not rely on the Good Faith Estimate for that information.
My true desire would be for this regulation to be completely dropped.
I would think it would take more than 3 days for someone to feel
they’ve been cheated. And if so, they would still have to
go through the legal process for restitution, therefore, what difference
does the rescission period make.
This regulation is an unnecessary burden on the lender, borrower
and possibly a third party to whom the loan proceeds may be going.
Thank you,
Kenrick Mathis, President
Texico State Bank