FACT Act Risk-Based Pricing Rule #534730-00001

Submission Number:
Norman C Barnes
Initiative Name:
FACT Act Risk-Based Pricing Rule
I have been in mortgages since 1969. A very learned J. Monaghan once said that "You will never correct delinquency by adjusting the interest rate". It is contradictory in philosophy. Where has sensibility gone. He went further to say: "Effective collection is in place with smart lending practices". I have seen all sorts of analyses of how we got to where we are and they seem to embrace what should not be done to promote stability. All sorts of price adjusters, mortgage limitations, product/program termination, collapse of an infrastructure which promoted competition has been suggested to cope with the problems. The sadness is that some products have been around for 30 years or more and have stood the test of time. It concerns me that rate adjustments made on a fixed rate product whose adjustments are timed based on proven increase in income have been modified to beyond the realm of sensibility. These buydowns had a place in the market and the FHA buydown was the "Cadillac" of all possibilities. To now require the individual to qualify at the final rate is like providing a Sundae without the Cherry on Top. Can you please analyze the duration of time the program has been on record before you monkey with it -- change for the sake of change nets marginal accomplishment. I believe if you wish to starve the people you cut off the food supply -- dehydrate cut off the water - housing make more cautious adjustments which are based upon pricing. If you want to improve profits of a company justify higher rates, let them then cutback their staffs -- what have you accomplished? Bombastic rates and heightened unemployment. Forgive me but knock, knock, is anybody home?