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  • Comment Detail

  • Date: 04/19/18
    First Name: Lonnie
    Last Name: Clark
    Organization: State Bank of Chandler
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    There needs to be a change to the program so that the member bank can be more certain that there either is or is not money allocated to that individual member bank for this Affordable Housing Program, as was the case in the past. The problem is the uncertainty. We no longer operate under RESPA with a Good Faith Estimate. We operate under TRID with a Loan Estimate, which is not at all an estimate. It is a Guarantee and we are bound by it. It does not work to tell a loan customer that we will offer help with a "grant" if there is money left in the fund. We as lenders, need some assurance that there actually is money available before bringing it up to a home loan applicant. You should switch back to allotting amounts to member banks that apply for it. If you are concerned that the allotted funds are not being used, then you can take back unused amounts on a monthly or quarterly basis and you can re-allocate them to other members. That way lenders could know with some certainty that there either is or is not funds available.