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Proposed
Federal Reserve Board Rule Contains
Provisions to Eliminate the Independent
Mortgage Broker!
We
need your help!
The
Federal Reserve Board has issued a proposed
rule that could dramatically harm your
business. All public comments must be
RECEIVED (not postmarked) by April
8. Review the information
and links below then follow the instructions.
Time is very short - get your comments
in today!
RULE
IMPLICATIONS
-A
new category of "higher-cost"
loans, which will eliminate all stated
and no-doc loans.
-New
APR triggers of 3% (1st mortgages) and
5% (subordinate mortgages) above the
10-year U.S. Treasury, causing nearly
every mortgage to be classified as a
"higher cost" loan. As such,
the provisions of the Fed Rule will
make financing nearly impossible.
-Requiring
all Mortgage Brokers to disclose, before
application, what your mortgage brokerage
fee (front end AND back end fees) will
be on the loan and this cannot change.
-Originators
must determine that the borrower has
the ability to repay the mortgage for
at least 7 years.
ACTION
NEEDED
Please
have everyone in your place of business
submit comments. NAMB has prepared a
3-page bullet-point summary with guidance
on writing your comments. To access
the summary, please go to www.famb.org/gaup/Comment%20letter%20bullet%20points%20grass%20roots.doc.
It's very important that you craft comments
in your own words following NAMB's suggested
points. In addition, a copy of the entire
Fed Rule can be found by clicking
here.
SUBMISSION
You
may submit comments, identified by "Docket
No. R-1305" by any of the following
methods:
E-mail:
regs.comments@federalreserve.gov.
Include the docket number in the subject
line of the message.
Fax:
(202) 452-3819 or (202) 452-3102.
Mail:
Jennifer J. Johnson, Secretary, Board
of Governors of the Federal Reserve
System, 20th Street and Constitution
Avenue, NW, Washington, D.C. 20551.
All
public comments will be made available
on the Board's Web site at http://federalreserve.gov/generalinfo/foia/ProposedRegs.cfm
as submitted. Accordingly, comments
will not be edited to remove any identifying
or contact information.
If
you have questions, please contact mamb@mamb.org.
This
is a critical time in the mortgage industry
and Mortgage Brokers must act NOW! Please
submit your comments today!
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