Mr. Miller,
Thanks for your quick response I'm sorry but I can't return with any real substance until this evening as my schedule is full for the remainder of today. I have a full list of clients to pillage (just kidding)
just a few quick notes though.
1) Biggest "quick fix" for the immediate problem.
National Mortgage Reform. Hint.... Take a look at Michigans' Procedure. It's procedures have allowed both consumer and lender to coexist peacefully, and has all but eliminated the "loan to own" lending in that state.
2) Rather than trying to keep the "rats" from Multiplying by penning them in, do it by making them compete for the loans with more lenders. Translation.....trash HOEPA we had a small problem before the law came into effect, we have a large problem now.
3) Further reduce the predatory lending consumer base through education. HUD and many high profile consumer advocacy groups decry the very problem they helped to create. HUD fails on two fronts regulation, and education. The consumers' groups efforts to "educate" those they wish to protect have failed miserably. Right now, their most effective tool would be a mirror, because an educated, and informed consumer base would not buy this product. They would be more inclined to do business with someone like me. Instead, they impulse buy after watching the T.V., then listen to the "rat" loan officer who preys upon their lack of self-esteem by telling them, that they could no one else would want to do a loan for them. From my past contacts with advocates and legislators I have get the impression that they feel their constituents (consumers) are stupid, and unable to discern that they are being taken. This condescending attitude makes me angry. Subprime clients are not stupid, just pooly informed about their options. Irrespective of racial or ethnic background, they were not taught credit management by their parents, and the various consumer groups have done a miserable job of getting this knowlege out to the communities they serve. Sorry, but aside from individual competitors, the lending industry is not, and should not be responsible for educating its consumer base. Their job is to sell more mortgages, within legal guidlines. The burden of educating the consumer lies at the feet of the community. ie HUD,Consumer Groups, Media. So far as I am concerned, HUD is only decrying its own failures. This goes double for groups such as "Consumers Union" If people don't buy their stuff, tough, then distribute it in the community for free if you are really that concerned.
4) Make the MBA and NAMB more responsible for the acts of their bretheren,and in turn, make membership to either association a primary indicator of a lenders' ethical status. If they belong to either association, that is a good sign. If not, be forewarned. We know what is B.S. and what is a real problem when one of our own is talking. We can weed out the bad apples faster than HUD could ever dream of, we , as associations have to have the guts to cuts out the "rats" from our associations so consumers can be given a readily identifiable "heads up" as to the ethical status of a lender.
I appreciate your earnest reponse to my last posting, however, there was one point that bothered me a bit. You mentioned that maybe some people should not own a home anyway. This is the same sentiment that was vioced by both Rep. Kennedys', and Sen. Reigles' offices when we were fighting the onset of HOEPA. I was as lost for a response then. Not anymore. To me, this is a response of someone who has never had a good person beset by a set of unfortunate circumstances, in their own office begging you to save their familys' home. Or, someone who has stumbled along in life because no on took the time to tell them that paying intermittantly was still a bad thing even though they eventually paid the debt in full. What about the newly widowed mother who needs a chance to consolidate the familys' debts and catch up on the house payment? Or the parents of a child accused of a crime that he did not commit, who have spent every last dime of their income, savings, and retirement,defending him and their only recourse is to pull equity from their home at whatever the cost. (The son was later acquitted in a short jury trial, and the prosecutor was reprimanded.)
These are all actual cases of mine. I ask you to come in my office, personally face these people, and tell them and their children that they don't deserve to own a home. Blanket pontifications are easy if you don't have to deal with the real people who are left out in the cold.