Comment from Meussner, John

Re: proposed changes to mortgage compliance regulations Since 2015 and the implementation of TRID, I (a mortgage professional) have seen unnecessary stress, delays, and financing burden placed on loan applicants. Several compliance rules, while well-intentioned, have negative impact on consumers without offering benefit or protection to the vast majority of consumers. Notably: - the requirement of APR disclosures in any/all marketing including "interest rate" or other triggers. This APR requirement is extremely difficult to get correct, as APR numbers can change based on information a lender does not know until after application (for example, lenders can skew APR by marketing based on a loan close date of the last day of a month - with reduced "per diem" interest in that time frame, the SAME LOAN can have a different APR than another lender marketing based simply on a different day of the month a loan is consummated. It's difficult & confusing for consumers to understand APR, and while it is a way to gauge costs, it's MUCH EASIER for consumers to see rate and total dollar amount costs, VS the APR figure that hardly anyone understands. APR should be included in disclosures, but should not be a foundational part of marketing and initial loan advertising. - rescission: 3 day rescission, IN ADDITION TO, the 3 day CD-delivery waiting period, is burdensome, and unnecessarily adds time (and lock days/costs) to the loan process. The amount of loans that rescind is immensely small, so this added protection actually protects a very small market segment, while adding burden, cost, and time to everyone applying for a refinance mortgage. My suggestion: Make it "either/or" - EITHER rescission, OR a 3 day waiting period upon CD delivery...not both. - redisclosure: the constant need to redisclose causes more confusion and disruption to consumers than it offers protection. The MAJORITY of mortgage customers esign and fail to read disclosures, but those who do are often confused by small, insignificant changes, and the amount of loan estimates that go out can be overwhelming. Further, the failure to quickly access an LE can result in additional timelines or delays in the loan process. Limiting the instances redisclosure is needed would be a good move. - the CD: The CD, and all of it's pages (then the "final CD", and the "post close CD" causes massive confusion to consumers - while designed to inform customers, the amount of information and the layout of the document cause confusion. The old "good faith estimate" and "final settlement statement" were far easier to manage for consumers - consumers care about their rate, their payment, and the dollars they're paying in closing costs - these items are easily shown in one itemized page. Get rid of the CD, it's worse than it's predecessor disclosures. - APOR thresholds - APOR thresholds and fee limits sound great - but the reality is that since they are based on percentages, they harshly penalize customers seeking lower loan amounts (since a flat fee is a much larger % of a small loan), and customers with less than perfect credit (thanks in large part to the sometimes enormous LLPA charges applied by FannieMae/FreddieMac on all conventional loans). APOR, using old data to set thresholds, also causes unnecessary delays and consumer frustration if rates move quickly (eg if APOR numbers from a prior week are being used in a week when rates have drastically, and quickly, spiked). Exceptions for loan amount and fast market changes should be available. - LO Comp - Loan officer pay, as a result of Dodd-Frank regulations, has become a nightmare and is often something that companies manipulate on a regular basis - a fixed % paid to a loan officer DISCOURAGES loan officers from working with or marketing to lower income/lower priced markets, and creates an environment where an LO must be paid more (or less) for the same level of work and professionalism, based solely on how much a customer wants to borrower - same process, same work, with exponentially different pay - this harms low income customers and customers in areas with low prices by reducing competition as lenders and loan officers often focus on areas with higher loan balances. LO comp should be flexible - a loan officer should be able to make more money on a loan application that takes them 40 hours to work through, VS a loan application that takes 2 hours of time to work through. As long as there is pricing transparency, pricing should not be static, as the amount of work (and overhead expense) varies drastically from loan to loan. The entire TRID rule, while well-intentioned, has resulted in no additional protections, higher costs for lenders (that are passed to consumers), and a more tedious and confusing loan process for all customers. Expenses have risen, and those increased costs have been passed directly to consumers, making housing more expensive.