Good Morning,

I understand why Countrywide and many other lender/providers are eliminating the HECM Advisory program. I am sure HUD will follow through and deem the program eliminated based on their present language outlined in the bill. However, as I have stated previously in the Post, the key issue is the interpretation of the word “Origination” as HUD uses it in the bill.

As long as I have been associated with the mortgage banking industry, the term “Origination” always meant the company and or the individual who took the application?

I feel eliminating the Advisory program completely is a major mistake on the part of HUD and our legislators. The problem we really have been facing us is HUD. If HUD had the ability to monitor and supervise the program properly, they would not be eliminating it. HUD and much of the industry is trying to blame the problem with the program on the advisor rather than on the lender/provider.

It is up to the lender/provider to screen a prospective advisor. It is up to the lender/provider to thoroughly train the advisor. It is up to the lender/provider to make sure the advisor is working within the guidelines for the HECM Advisory program set forth by HUD. It is the responsibility of the lender/provider and their representatives to stay in close contact with their advisors. I ask ALL of you reading my comment, are all lender/providers being responsible and doing what they are required to be doing under the guidelines set forth for the advisory program?

The HECM Advisory program is a good program if handled the way it was intended to be handled. HUD has people on staff who do not even understand the program but are trying to administer it. Our legislators have no earthly idea what they voted on when it came to this part of the bill. Many of the lender/providers are abusing the program and do not understand it themselves. What we have are a lot of lazy people trying to find the easiest way out. HUD and our legislators see the easy way out is by eliminating the program. Many of the lender/providers find it an easy way to make a quick Buck, so, they take the easy way out and do not do their jobs according to the rules, regulations and guidelines. It is very sad, just like the whole Housing Recovery bill is.

We live in the greatest nation on earth, I love my country dearly and served it proudly. However, I don’t like what I am seeing happening to our great nation. We the people must realize, the change that is needed in this country is not just going to happen unless we make it happen. Are we still capable as a nation to be strong enough to take this country back (BY THE PEOPLE AND FOR THE PEOPLE) the way our forefathers intended it to be?

Thank you and best regards to all,

The Great American Philosopher

http://www.thegreatamericanphilosopher.com

BY: John A. Smaldone, johnsmaldone@charter.net

Jerry,

Please remember who takes the loan application and really originates the loan, it is the provider, not the Advisory account. The Advisory account is only supposed to advise. I have heard that some providers were sending a completed application to an Advisory account and the Advisor went to the seniors home to take the application. This is outright against all the regulations that governed the HECM Advisory program.

You are not getting it. The provider, the Lender that signs up an Advisory account is responsible for the taking of the application, processing the application, coordinating or doing the underwriting and coordinating or actually funding the loan. The Advisory account is not responsible for this major function in the process.

It is also up to the provider to train and educate the Advisory account they sign up. This way the Advisory account will have enough knowledge to be able to communicate to the prospective borrower. The Advisory account can’t commit the wrong doings HUD is outlining. HUD eliminated the program blaming the wrong entity. If the provider understood the HECM Advisory program the way they should, we would not have problems with the Advisory account itself, it is that simple. I appreciate your reply Jerry, have a good day.

Best regards,

The Great American Philosopher

http://www.thegreatamericanphilosopher.com

SPONSORED BY: John A, Smaldone

Jerry,

You make a lot of sense and bring up good points. I agree with you, this is anything but a perfect world. However, any program that a bank, broker, mortgage banker etc. puts out to the consumer must be regulated and supervised by some one or some regulatory agency.

By eliminating the Advisory program is not eliminating the problem. Originators and companies will come up with another way to skin a Cat. I would rather revise the Advisory program and make it more stringent then doing away with it completely. Thanks for replying back to me, I appreciate it.

Best regards,

The Great American Philosopher

http://www.thegreatamericanphilosopher.com

SPONSORED BY: John A. Smaldone