HUD's Good Faith Estimate and Sttelement Statement Need Continued Resistance by Those Who Care!
Just because HUD has told the entire industry that its been decades in the coming and we can no longer wait for the solution offered by the implementation of the flawed Regulation X changes, it does not mean that we should simply give up the fight!
IMMAAG is the first to admit, this effort is the epitome of "Tilting at a Windmill". IMMAAG has been ignored by one HUD RESPA staffer, handed off by a RESPA manager and told by another that there is no way on earth that anything can stop the change being implemented on January 1, 2010.
We have also heard hundreds of our friends and industry partners simply sigh and say they're through fighting. “Let's accept our fate and go on with accommodating the use of the new forms and processes that have absolutely no hope of achieving the shopping and disclosure objectives of either Regulation X or Regulation Z.”
But, you know what? Even if we don't have a chance to change 1/1/2010. Even if we're stuck using our own additional, understandable and transparent disclosures to help our customers make informed decisions, we will do what is required because we are professionals. But, in doing that, we can't just give up because people who have never had our responsibility have decided they know best.
IMMAAG asks you to please, join with us. It may not stop 1/1/2010; but it will let HUD know we have a better way.
Even if it is a "done deal" . . . . Even if it is "signed, sealed and delivered". . . .
Let's give HUD an alternative that can work.
If you want to read the letter IMMAAG sent to HUD's RESPA Director, Ivy Jackson on December 28, 2009 just click here.
If what we said in that letter resonates, then become one of the thousands we are asking to join us in telling HUD as far as we're concerned the customer is important enough for us not to give up on them.
Click here, copy our Position Statement and Conceptual Shopping Tool and take the 10 minutes necessary to send it as an attachment to an email from you to Ms. Jackson. In your email ask her to at least consider the alternative and to consider stopping this process until HUD and the Board can vet our proposal and consider how Regulation X and Regulation Z could both be served and at long last produce disclosures that enable them to meet their consumer objectives.
Ms. Jackson's email address is: ivy_m._jackson@hud.gov (Underscores the "y" and after the period following "m")
Thank you. Maybe it is a Tilt, but it is one that is worth it!