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In the interest of further simplifying mortgage transactions and making them easier for consumers to comprehend, I'll follow the U.S. Department of Housing and Urban Development (HUD) and its model of "more is better," a philosophy proven by the new HUD GFE required as of Jan. 1. Although that GFE spans three pages — two pages more than the "old" one-page GFE — I'm going to step it up and increase my initial-disclosure package from 23 pages for a conforming, 30-year fixed-rate loan to 70 pages. My 40-page initial-disclosure packet for Federal Housing Administration loans will grow to 120 pages.
To ensure that borrowers have time to digest this new volume of clarity, I'll borrow a page from the Mortgage Disclosure Improvement Act. Given it takes an additional three business days for consumers to understand the new "simplified" disclosures, I will mandate nine business days to understand mine. Don't go worrying about any negative effects this might have on consumers' rate-lock. If the federal government doesn't take that into consideration, why we should we?
Finally, to guarantee a level playing field across all origination channels, the required diligence to these measures will be directly proportional to the size of mortgage bankers' and mortgage brokers' disparate lobbying budgets.
Therefore, as with the Secure and Fair Enforcement for Mortgage Licensing Act, the largest financial institutions will simply have to register their originators and state they have intent to comply. The smaller entities — that means you, mortgage brokers — will be required to keep three copies of the new disclosures on hand, complete coursework roughly equivalent to that of a master's-degree program annually and allow background checks on each member of their family. This will permit regulators to make sure you're licensed and properly qualified to originate home loans.
Yep, these changes will surely repair the industry. After all, better to create new laws and disclosures than to obey and enforce the ones we have ... or is it?
Adam Stein, executive vice president of Cascade Pacific Mortgage Co., is past president of the Washington Association of Mortgage Professionals, CEO of Integrated Mortgage Origination Systems, and president of Federal Homes and Real Estate. He sits on the Conference of State Bank Supervisors' Mortgage Advisory Council and the Washington state governor's Task Force for Home Ownership Security. He spent two terms as chairman of the Washington State Mortgage Broker Commission. Contact (800) 874-8760 or firstname.lastname@example.org.
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