[David] and move on to Alice Alvey with an update on legislation. Alice, what you got?
[Alice] Hello, everyone. So for today, it’s a reminder that this is your last day to submit your comments for the request for information that the Consumer Financial Protection Bureau has out there regarding the Truth in Lending Act. And really, the whole act, the Truth in Lending Cons- TRID, TILA-RESPA inter-integrated disclosures, they’re all on the table for you to be able to submit your comments. When I last checked last night, there were about 260 people had commented. I started sifting through them. I was surprised how many title companies have responded, and what I notice about their responses, it’s very focused on, they’re that last step in the process and all the consequences that they have to deal with TRID. What I would love to see is more mortgage companies get out there. I’m gonna keep sifting through. Hopefully, you’re out there and you’re actually commenting on specific fee issues involved in the tolerances. That’s something the title companies can’t do, right? Only mortgage industry players can get out there and say, ” We need these changes to these types of specific fees in order to make these disclosures easier.” Telling them they have to go back and redo the entire disclosures, I don’t think any of us wanna go through all that again. But getting some changes so that re-disclosure is less frequent and less full of fines and penalties, that’s one aspect. What I chose to comment on, I did publish my comments, and so those of you who are listening, if you’re interested in trying to make changes to the right of rescission rule, that’s the band that I commented on. I really do feel that this rule was put in place for home improvement loans, problems in home improvement financing back in the ’60s , right? That is a long time ago. Financing, disclosures, everything has changed dramatically since then. So keeping it with what its original purpose is means that today we should not be having a three-day right of rescission when the borrower’s getting everything they need with the proper funding three days ahead of closing for their refinance, and just we really don’t need this extra waiting period. The consumers don’t want it, so one recommendation, at least from our perspective this group here, we’ve talked about that in all of our experiences we have what, 250 years of experience on this topic podcast maybe more we were all on the same page that, consumers don’t even know what this is, and they don’t exercise this right, and they don’t care about it. They really just want their money, want their closing, and want it to be done. So it was let’s get this cleared up. Let’s remove this rule, except for some of those high risks. I understand high-cost mortgages should retain this potentially, and also potentially your home equity lines of credit if that was the issue for home improvement financing. So still keeping, the narrow band that the original intent was, but not expanding it to all refinance. Rate and term, cash out, we don’t need three-day right of rescission with the way the disclosures are upfront today. The customer knows the costs. We’re doing fixed rate financing these days. The consumer really is not at risk and they seem to not want this. So let’s get a study done, let’s get it right, and let’s get rid of it. So you can check out my comments. You can simply say in your comments that you agree with me, or disagree, that’s totally fine too. But if you do agree and you’re going, “Oh, I don’t wanna write my own letter,” you can simply say that in your comments, and you just go to the Federal Register, and you can also check out what other people have said as well as myself. I didn’t get a chance to sift through all of them. Maybe MBA has already commented, but they usually issue a notice once they’ve published so maybe they’ll be getting theirs out later today or first thing tomorrow we’ll hear about it. So that’s my report today …
[David] Where were your comments posted, Alice?
[Alice] I posted with for the Consumer Financial Production Bureau’s request for information. You did it, yeah. We all go in and we can post our public comments. Okay. And so I have posted my letter in response to that RFI. Good. Mortgage disclosure request for information. Very good. Sorry, I didn’t make that totally clear up in the beginning.
[David] That’s very good. That way people know where to go and-
[Alice] I’m assuming people are listening to last week’s show, and they know that part already, Dave. Thank you, yes. We have a lot of people that listen. New people joining each and every week. Yes, thank you, Alice. I know, I’m sorry. No, you’re good. I should’ve clarified that better in the beginning, but thank you for bringing that back up. [David] Good. Great. Go ahead and add. Just do this. Agree with Alice. We all do. That’s pretty fun. All right, very good. Thank you, Alice. Enjoy the rest of your day.
Alice Alvey, Master CMB
She handles development of their World Class Training program designed to support UHM partners and organizational effectiveness.
Prior to UHM, Alice served as Senior Vice President at Indecomm leading the Indecomm-Mortgage U division, Internal QA and Compliance and SaaS technologies. Indecomm acquired Mortgage U in 2013, where Alice was President/Co-founder, providing training and consulting since 1996. Prior to MU she served as SVP of Operations at a national bank overseeing operations for wholesale, retail and correspondent from underwriting through servicing, and compliance.
She has been in the trenches of mortgage lending operations from application through servicing for over 30 years. Her authoring work in training content, policies and procedures and the FHA/VA Practical guides illustrates her ability to bridge regulatory requirements with day-to-day operations.
Alice has been a weekly contributor to the Lykken on Lending show since its beginning in April 2009 and has made her weekly contributions to 450+ episodes!