Comment Detail
Date: 07/25/17 First Name: Jeff Last Name: Meyers Email: jeffm@uccu.com Organization Type: other Organization: Utah Community Credit Union Comment
I've worked in mortgage lending for 17 years and manage a large mortgage operation in Utah. I am writing to urge you not to amend the Uniform Residential Loan Application (URLA) to include a question on the language preferences of potential borrowers. Such a question could create an expectation that we will be able or should be able to service them in their preferred language. This is not a reasonable expectation and would be nearly impossible to manage. It would open our operation to scrutiny should we not provide them service in their preferred language. Even worse, it may lead a borrower to erroneously believe that they are possibly being discriminated against or that providing this information may be harmful to their loan application. Neither outcome is consistent with the type of service we try to provide.
If the goal is to collect information, perhaps that would be better done by utilizing the immense amount of demographic data collected through the new HMDA rules. It would be unwise to include an inquiry into a borrower’s language preference on the URLA as it will result in more confusion for borrowers. I urge FHFA not to make this change.