HUD’s New Reverse Mortgage Counseling Protocol Includes Test For Borrowers

image Along with the recent changes to HECM counseling, the Department of Housing and Urban Development is expected to unveil a new counseling protocol next month to help borrowers asses whether a reverse mortgage is the right choice for their financial situation. 

The new protocol will include stronger assessment tools as well as the creation of a new HECM counselor roster.  All counselors who wish to continue counseling seniors will need to pass an exam, thus demonstrating their knowledge of reverse mortgages.

Counselors will be required to conduct a thorough financial analysis of each client to help understand each borrowers individual situation.  According to a statement from the National Reverse Mortgage Lenders Association, counselors will have the authority to withhold counseling certificates if they feel the borrower fails to comprehend basic reverse mortgage concepts. 

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Counselors will ask 10 question from a list of 20 items published in the protocol and borrowers are required to answer at least 5 questions correctly to be eligible to receive a certificate.  If borrowers fail the test, they’re required to wait a minimum of 7 days and then undergo a limited counseling session to address the topics missed on the test.

The 150-page protocol covers:

  • The role and responsibilities of counselors
  • The steps of counseling
  • Client needs and circumstances
  • The features of reverse mortgages
  • Financial alternatives
  • Reverse mortgage counseling tools
  • An appendix of HUD counseling policies

Besides the new testing aspect of HECM counseling, HUD is mandating that consumers receive a loan comparison sheet, amortization schedule, and a booklet published by the National Council on Aging titled Use Your Home to Stay at Home prior to the session.   

Sue Hunt, a housing counseling manager with Consumer Credit Counseling Service of Greater Atlanta, said that allowing time for these documents to be read prior to the counseling session means that it will take long for counselor to schedule meetings with borrowers.

I think certain aspects of the new protocol are good, but the new testing element of HECM counseling seems to put more pressure on seniors.  "Counselors giving quizzes doesn’t feel right to me as many of these seniors are anxiety ridden from all the stress they are under and it seems unfair," says one HECM counselor.  "It is almost like they have to justify themselves to us".

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  • A comment from an old timer…

    I am not sure when it happened, but I remember when I first started offering reverse mortgages that the counselor and the originator worked together to assist the senior client with the entire reverse mortgage transaction. I would send a senior information including a list of local counselors, an appointment would be made for counseling and, horror of horrors, I might just drive my borrower to counseling and sit in and hear what the counselor had to say. It worked. there was a transparency in the entire transaction. Heck, we might even call the counselor back if the client had some questions mid processing to help with. Often, our counselors would go to closing just to make the client feel better.

    We could call the counselors for help with difficult situations, and problems with repairs, payoffs, etc…they were happy to help. I am not sure when it changed, but at some point, the lenders became the enemy. Like we were the subprime lenders lurking about seniors looking to take advantage. I know that there are bad apples, but for the most part, the originators that stay in this business are making a living, but do this loan because they love it. If we worked out how much we make on every loan by the man hours it took to get the loan closed, many of us are making barely above minimum wage. We do it, because we love the seniors.

    Once again, we will all suffer because of the acts of a few. We need to find a way to take control of these regulations, and inform the regulators about the specifics of reverse mortgage lending.

    Thank you

  • For the Critic,

    There are actually several questions that touch on reverse mortgages in the state tests that I have taken. Additionally there are a lot of questions regarding FHA programs, fraud and state /federal regulatory as well.

    I am not suggesting this totally prepares you to offer a reverse mortgage and know every aspect about the program, however it is certainly a step in the right direction and shows that you understand the fundamentals of lending business.

    You are suggesting there should be a specific test for loan officers to take on reverse mortgages before they are allowed to offer to the general public.

    A reverse mortgage is simply another loan product that a loan officer might have at their disposal. It is the loan officer’s responsibility to learn and understand the products he or she decides to offer their clients and the state and federal regulations that go along with it. This is what separates a successful professional from one that does not take the time to understand what they are offering and generally won’t last in the industry very long.

    I personally would have no problem with taking some kind of an exam to prove I understand the reverse program inside and out however where do you draw the line? Should I be required to take a test on every loan program out there? Are we going to require every plumber, landscaper, auto mechanic to take mandated tests?

    At some point to much government intervention strangles and suffocates the people trying to provide a service.

    The state has licensed me to offer loan products based on the education I have received the tests I have passed and a thorough background check.

    They have the right to revoke my license at any time if they find I am not following all state and federal mandated regulations or am fraudulent in any way. Federal regulators have the same authority when they audit lender.

    I believe the fundamental idea behind CLA as well as the SAFE program is to get every state to participate in a standard across the country. I will be up to the states to still enforce not the federal government.

  • @ ReverseQueen

    You could not have said it better. I find myself wanting to leave sarcastic comments to some of these postings because of the seemingly unending march over the cliff this program is taking.

    When I first got started I “horrors of horrors” went to the office of my local counselor and took her and the agency’s Director to lunch. It was all about working together to help the senior. It does not feel that way anymore. You nailed it, a few bad seeds and the solution is impose draconian new rules, more restrictions more & more government. The government will solve all the problems and tell us how much we can make, and we will all say thank you sir may I have another. How about we just punish the wrongdoers?

    It is nice to see Peter Bell posting here and I find his comments instructive. I am intrigued that Peter does not understand how little information about the decisions and decision making processes that affect all of us as loan officers is disseminated.

    I also feel the “well it could have been worse” attitude needs to stop. If you are a loan officer in this business you need to start contacting your congressperson directly.

    http://www.usa.gov/Contact/Elected.shtml

    NRMLA will not save us from everything.

  • Reverse Queen,

    A great job in explaining what it was and what it should still be. It is sad we can’t get the powers to be to listen to plain old common sense, isn’t it?

    We can’t continue to go back wards as we are going. It is making it very difficult for us to do a good job for our seniors. Simplicity is needed the most in our industry, especially with all the confusion within our country and abroad. Wake up HUD, wake up FHA and wake up committee members. You are all becoming the problem, not the solver of problems.

    Best,

    John A. Smaldone

  • Peter, I understand that NRMLA might have helped in what is now our fees structure, but where is it with everything else? Everything that we are all discussing here seems to be getting handed down to us from lawmakers and powerful organizations like AARP and nobody INCLUDING NRMLA is taking the time to really listen to the people that are doing these loans, US! And I might be missing something but when did Reverse Mortgages become about being financially qualified? There are no income, asset or credit score qualifications needed to get a RM so why are the counselors getting into this area? Sure most of our clients use this as a way to supplement their SS or small pensions and with the economy like it is, actually save their homes but when did it become necessary to have to be in financial dire straits to be eligible for one? I was always under the impression (and apparently I am wrong) that counselors were there to make sure the seniors UNDERSTOOD the program and how it worked, using the equity to make the payments, options for receiving proceeds, fixed vs. adjustable, immortalization tables, making sure I did my job in explaining this all to them, when did this all change?

  • All of the topics that are discussed in this thread and others on RMD are being actively worked on by NRMLA. For those who are wondering what NRMLA is doing in each of these areas, our conferences, publications and member bulletins are the place to find out about them.

    Our upcoming conference in Chicago the week after next will include discussions on counseling issues and policies, HUD’s financial analysis of the HECM program and the impact that might have on future mortgage insurance premiums or principal limit factors, federal legislation, state regulatory and legislative activity, cross sell restrictions, and more. So, if anyone is interested in hearing all that is going on your attendance is encouraged in Chicago or Orlando the following month. Just under 200 people attended last month’s conference in Boston and the event recent rave reviews from just about everyone in attendance.

    If you are not able to attend an event, audiofiles of sessions are available for download from our website, so the information is generally available to both attendees and non-attendees alike.

  • Thank you, The Critic, for your comments about working together through NRMLA.

    As far as we are concerned, NRMLA is a reverse mortgage industry association. We don’t see any difference between “lenders” and “originators.” You are all part of the same industry. In fact, the large majority of NRMLA members, and most of those who participate in our meetings and programs, are actually correspondents, so I’m not sure why some feel that there is this schism between “lenders” and “originators?”

  • I agree with Travis DeRenzo on accountability. Let’s clean up our own industry rather then wait for issues to hit the fan. It may save the industry in the long run. A clearing house to report abusers would help. Then they could be referred to the proper agency with follow up. Could NRMLA help?

  • Great comments on this subject. I am concerned that the entire point of these possible counseling changes can have a profound impact on our seniors.

    For example, you are working with a client who has been notified they are going to foreclosure. The client is scared to death to consider being homeless. You are compassionate and are trying your best to reasure them all will be well. You explain they must take HUD counseling (which is fine). Your client contacts a HUD counselor only to be faced with even more pressure and stress, even as the process is currently done.

    Our seniors do not deserve the repercussions of any additional burdens placed on them for yet another, unintended consequence.

  • Critic

    You had some very good comments but nowhere did I state that that NRMLA created the current situation. I was just asking what they are doing to address the issues and I didn’t seem to be getting any answers until now!

    Sometimes when you ask questions you do get answers. I was happy to see Peter Bell correct you on your assumption that NRMLA just represented the lenders.
    Everyone is now aware that NRMLA is representing originators on the important issues or at least we hope so.

    The NRMLA website keeps us updated on current roadshows, mortgagee letters, HECM endorsements etc. but nothing was ever mentioned about the margin increases . It seems to avoid anything that might be controversial. Things could quite possibly be going on behind the scenes but as members don’t we have a right to be kept informed? I beleive we should also call it as we see it. I don’t know about a schism between lenders and originators but lets face it lenders do have interests at stake that is not always in the best interest of the originators. I didn’t see any lenders chiming in about the margin increases! So my question to Peter Bell is how can one organization equally represent lenders and originators when what is in the interest of one party might not be in the best interest of the other.

    My other question is who makes up the board at NRMLA. Are originators equally represented?

  • Good day,

    Sam, I could not agree with you more. Take the example of the borrower you mentioned going into foreclosure. If for some reason that borrower did not answer 5 questions right, another delay and more stress added.

    If the Post is accurate on what they are reporting, this proposed rule will be very damaging to the seniors and the industry.

    It seems like our Governmental bodies like HUD/FHA and individual states think they are imposing all these new restrictions and rules to protect the senior. The only thing that is happening is the creation of confusion and fear in the Hearts and minds of seniors and those of us that are their to serve and help the senior.

    Over the past few weeks I have seen some very foolish decisions and proposals perpetrated on the Reverse Mortgage industry. I have to wonder what or who is behind the thinking and actions of the likes of FNMA, HUD, FHA and the individual states. Lets hope common sense starts returning again soon.

    Best regards,

    John A. Smaldone

  • John Smaldone:

    If you think the restrictions are bad now here is something else to be concerned about.

    If you read Peter Bell’s comment you will notice that part of the agenda for the upcoming Chicago conference is ” HUD’s financial analysis of the HECM program and the impact that might have on future mortgage insurance premiums or principal limit factors ”

    Could this analysis mean raising the MIP and lowering LTV’s? Don’t be suprised?

  • Treverse (and all RMD readers),

    You can find a list of the NRMLA BOD members on the web at the following URL: http://nrmlaonline.org/nrmla/board/board.aspx

    What you will find is a BOD with a geographically diverse representation of correspondent/broker company owners, originators, senior exec’s at larger firms, and operations/servicing experts.

    I can’t stress enough that NRMLA is a membership organization, and that I and all others that serve on the BOD serve voluntarily and at the will of the members. I thoroughly enjoy the work, am passionate about our industry, and would welcome any comments (positive or negative) about the work that NRMLA does on behalf of the industry.

    Joe

  • Treverse and all that is reading my comment,

    I am aware of Peter Bell’s comments and the part of the agenda you are referring to. I can only hope you are wrong in what you think may happen.

    HUD, if anything, needs to look into the past and analyze what the Reverse Mortgage industry was five or six years ago. I feel very strongly about the statement I am about to make.

    We need to re-wind the Clock and take the industry back five years. We need to keep all the great components of the programs and benefits to the senior we had. The only items in my opinion, we need today, over what we had five years ago is the following:

    1. The higher lending limits of today for the HECM.

    2. The 120 day lock protection of the expected rate.

    3. The changes in the appraisal approach.

    4. The additional HECM programs added.

    5. The abolishment of the Homekeeper.

    6. The curtailment of the proprietary products.

    If anything more is needed today, it is NOT what has been dished out to the industry thus far. I have my opinions on what we do need, that will be for another day?

    Five years ago the senior was not as educated about a reverse mortgage as they are today, that we know. However, we as Reverse Mortgage Specialists new our product and we counseled the seniors well. When the senior entered into an application they were comfortable about it because of the good job we did for them.

    Today, we have mass confusion on our Hands. We have more people than ever in the industry, people that should not be in the industry, Reverse Mortgage Specialists know less today than they ever have, FNMA, HUD and you name it has made more stupid decisions than one would have ever imagined, I could go on and on.

    I know this is question is not very original, but, are we really better off today than we were five or six years ago?

    Thank you,

    John A. Smaldone

  • Critic,

    I appreciate your comment on my quote. However, I brought up a lot more than a nostalgic overview.

    The point I was trying to make was, the industry, the agencies and even the states are trying to do an overhaul on many sections of the Reverse Mortgage way of doing business. However, it is not benefiting the senior or the industry at all. It is making it more difficult to do business and more difficult to understand how to do business. Also much of what is being proposed or have been put into affect is contradictory to what many mortgagee letters that are active and not repealed say.

    The Reverse Mortgage industry is very different from the traditional lending industry. However, movement seems to be going closer and closer to the forward side of the mortgage world.

    I am saying we CANNOT take the Reverse Mortgage industry and turn it into the same way of doing business as the forward world, it will not work.

    I was reflecting the past because we need to turn back the Clock and return to many of the rules and regulations that governed the industry before.

    I realize we must go forward but not in a way that we will revolutionaries the Reverse Mortgage industry.

    We now have FNMA, who brought live pricing to the table, they now are raising margins and they are turning commitments into mandatory delivery pools rather than a best effort delivery. To make matters worst, we now have HUD trying to revolutionaries the counseling procedures.

    No, My statement was not just about the past or having my dream come true as you put it. If that is what many who read my statement walked away thinking, than I did a poor job in trying to convey a message to our readers. I hope this response clarifies my position and clears up any misconception one may have had in reading my previous comments.

    I agree with you Critic, we have a lot of tough work ahead of us. We need to bring some simplicity back to the senior, the HECM programs and the Reverse Mortgage industry before it is to late for us to do any thing about it!

    My best regards,

    John A. Smaldone

  • Critic,

    I enjoy exchanging views with you as well. I am sure we have both learned a lot from one another, I know I have from you. Let me try and answer some of your questions, which are good one’s by the way.

    First off I did not call out NRMLA, it sounded like you felt I did? I understand what you are saying about as far as not being able to fight all fights and win all battles. AARP is a tough one, I understand. You are right, the compromise is much better than what AARP wanted.

    As far as HUD and FHA re-winding the clock back in time, sure, HUD, FHA and FNMA can do it. They can eliminate some of the damage already done by what they have implemented. They could also not go through with some of the future items on the agenda that will hurt the industry even more. Critic, you hit the Nail on the Head! It is those who are overseeing our industry today that is blocking any movement to look back and see what worked in the past. They can and will only focus on the direction they want the industry to go in. I do not feel it is for the good of the senior or the industry but for their own good only!

    We as an industry need to unite and designated a panel of educated people who understand the Reverse Mortgage industry from Soup to Nuts. This panel needs to outline what the Reverse Mortgage product and industry needs to function smoothly. The panel needs to outline what will work for and benefit the senior with our products. The panel will have to outline in detail what needs to be eliminated, what needs to remain and what needs to be added.

    We are starting to become disorganized because the people who do oversee our industry are implementing changes that are doing more harm than good. It is coming at us from all directions. FNMA has been a major cause of confusion and unrest in our industry. Over the past six months they have implemented changes that have disrupted the RM industry something terribly. This panel will have to get our senators and congressmen involved. The panel will need the strength and support of a NRMLA so we can bring our problem to the attention of legislators and the people of the United States of America. This is one way of bringing the people who are the overseers and the one’s damaging our industry to their knees. I may sound a bit radical but many people and governmental officials out side our industry do not know what is going on. We need to inform them and get them involved.

    The one who makes the loudest noise sometime are the one’s that are heard! I would go as far as getting the Associated Press involved, especially if we can bring into play our senators and congressman?

    Let me answer your questions about the Proprietary programs and the Homekeeper. As far as the Homekeeper, the only way it would and could work, in my opinion, is if the lending limit were higher than that of The HECM. Also, the LTV would have to at least be equal to or exceed the HECM’s LTV actuary calculations. The only way that will happen, is if the PMI companies would come out with a program to insure the loans with the same or higher LTV than the HECM has.

    Critic, it is not that I don’t like the Homekeeper or proprietary programs, they just have not done the job. The Homekeeper and proprietary program had some very good features to them. Take the proprietary programs, they did fill a big gap before the national HECM lending limit went into affect. Who knows how long after 2009 that will remain?

    In my opinion only, I feel the proprietary program, to work today, needs to have a much higher LTV and we need to have a demand for the product in the secondary markets. With out those two components, I can’t see the product being useful. I know there are programs on the drawing board and their are investors in the secondary trying to figure out what structure will work to securitize the product, maybe in the near future we will see a good proprietary product surface.

    I hope I answered your questions? You are right, we may not agree on everything, but that is a good thing. What is important is that I feel you and I share the same philosophy. At the end of your comment you gave me a compliment and said “I had the right Heart in these matters”. You do as well Critic, that is why I enjoy your comments and sending back to you a nice long reply like this one. You and I as well as all the other caring and knowledgeable people I have seen comments from, need to stick together and figure out a way to win. We have a candle to carry for our seniors and the Reverse Mortgage industry as a whole. We cannot allow the type people you mentioned destroy our industry, the seniors industry.

    All my best to you,

    John A. Smaldone

  • Critic,

    Thank you. As to the Homekeeper product, you are right, the Homekeeper did fill that void. You are also right on the new HECM limits not helping those in the upper category who is really needing them.

    I agree that we need a proprietary product that is functional. What we have seen during the fade out of the proprietary product was, LTV’s going down so far, they became useless. They became useless because the LTV drop also was followed by a ceiling on the amount one could get as the principal limit.

    This is where we can turn the Clock back. If we could get investors to come back into the market, securitize a product with at least a workable LTV and with balances that will be able to be used for the $2M to $50M home value, we would have something again.

    Before I go, what did you think of my idea on forming a panel for the purposes I outlined in the last comment to you? I would be interested in your thoughts on it. Have a great day.

    My best,

    John A. Smaldone

  • Critic,

    I sent you a comment reply to the first message you sent to me. This was before reading your 2:03 PM comment. By the way, I think you have me mixed up with someone else.

    You said the initiator and myself were going to follow up with NRMLA on the credit line issue. That was not me that said that, please check your records.

    As far as the task force, you are right, it would be a large undertaking. If you read my comment on that again you will see the panel I spoke of was not going to be a decision making board but one that would be a panel that would draw up a proposal for the RM industry and the path it should take. I stated we would have to have the backing of senators, congressman and NRMLA in order for us to be heard.

    I know this could not be a panel to make decisions, I am sorry if it appeared that I was eluding to that. I wish I had a Crystal Ball and knew exactly what to do but I don’t. Mine was a suggestion. I do know this, something has to be done.

    You said a lot in your last comment. I thought you put it in prospective very well, for the most part. I know a panel like I spoke of has to be structured and a well thought out plan would be needed. It does not necessarily have to be a costly project. An idea first starts with a thought, then it has to be put together like a puzzle. If the thought makes sense, then it will be worth putting the puzzle together.

    I was only fishing and thinking out loud to you with a thought. You enjoy your evening and I look forward to future conversations.

    Best regards,

    John A. Smaldone

  • Critic,

    On the first issue. I can’t give you an up date. I never communicated with the initiator but I know of his comments. I think someone else along with the initiator said they were going to contact NRMLA. By the way, don’t feel bad, if it were not for posties my memory would always fail me.

    You are right about what my intentions were with the panel, a “Think Tank” is a great word for it. My hopes were if the think tank worked, we could try and get enough senators and congressmen to listen. I can’t argue the point that it would not be easy or would it do any good at all, as you stated.

    There is nothing wrong in different styles, we need it. Believe me, I am different in my style as well.

    As far as the call Sam is going to have. You are right, it will not help the present situation or the loss of proceeds you are and will be experiencing with your senior borrowers. It is a sad thing we are facing, especially for those seniors that have critical financial issues. A $5,000 loss of proceeds could make all the difference in the world to a senior who may be facing foreclosure, as you so well pointed out.

    What is very frustrating to me and I know it is to you as well is that we are handy caped. We can’t do anything about it. We can only console those the best we can. Will they ever trust us again, most likely not. Our pain will be to watch the suffering the senior will go through. Sam’s conference call could do a lot of good for the future. I know I have at least one senator and one congressmen that will be on the call. I intend to try and have more. I believe it is Sam’s intentions to invite other senators and congressman. We need the right people to listen and understand the real issues here. Until we get the right Ears listening, we are not going to get any where. That is my opinion for the night.

    You really put me to work today, but, I enjoyed it. You understand the business well and you have the compassion for the senior and our industry. I am always honored to go back and forth with you on the issues, we are definitely on the same team. You have a good evening and thank you.

    Best regards,

    John A. Smaldone

  • There certainly is a fine line between being protective of the seniors with whom we work and treating them disrespectfully or like financial babies.

    I have had conversations with many prospects who don’t necessarily need the proceeds to survive but WANT the money available to them for whatever purpose. It is, after all, their money.

    Having a counselor, who is probably not a licensed financial adviser, making decisions about who is appropriate for a reverse mortgage sounds insulting to me.

    As a loan originator I see it as my job to make sure that I have explained every single detail about the program, the products, their choices and the ramification as well as the process before we ever get to the point of the “official” counseling which it seems to me should be just a rewrap of all of the information that has already been discussed in detail.

    It is easy enough from the get-go to determine if a customer is impaired simply by paying attention to whether or not they are understanding, remembering and tracking what is being said. I always ask a customer if there is POA and if there is any doubt about cognitive functioning I suggest that we include a family member who can be there for them through the process.

    My last 2 customers endured 1 1/2 hour counseling sessions where they were asked personal questions about health and hygiene, family and social arrangements and an abundance of personal questions that have nothing to do with a reverse mortgage. And to top it off, one of the counselors told my customer that the MIP was negotiable. (Banging head on table).

    Could we please stop scaring our customers and not request that they walk the plank before completing a transaction that THEY have requested?

  • the test seems to more about testing the housing counselor as to how well they were able to educate the client than anything else and I think it is very needed

  • Seems to me they are saying our Senior are uneducated and unable to know whats best for them. I don't see the same happening to forward borrowers. We are talking about people that have paid off there homes & obligations, responsible people. They thought they would live out there lives on penions,investments,SS and as we all have found out thats not happening today and age has nothing to do with it. These people are proud and the last thing we need to do is make them feel they have to beg for help.. I think it might be time for this honest, caring Reverse Mortgage Originator to change careers this saddens me… I'm glad my mother got her reverse mortgage years ago..

  • Question_Mark,

    I appreciate your reply and I would not expect everyone to see eye to eye with me all the time, I respect you for saying that.
    It is imposable to roll the Clock back but their is nothing wrong in using some of the good that was used in the past coupled with the changes time creates.
    Three or four years ago our industry was not looked at or considered predatory or the next sub-prime industry because we were not. In fact we are not now but certain factions and legislators are making us out to be.
    the proposed bills and some of the new legislation passed has has not only made us less effective than we were but it has also turned us into looking like a greed monger industry like the forward industry has become. Believe you me, we are not that type industry!

    You make a lot of sense in what you say, I enjoyed reading your views on my opinions, many made sense. Please do not think what you might say would be disagreeable to me, on the contrary, I appreciate you for saying what you feel and
    combating my views if you see them differently.

    We are in very troubled times, our industry and most definitely our country. We have no choice other than whether the storm but we can do all we can to fight it when it is wrong for our clients, the seniors. Thank you Question_mark, you have a good weekend.

    My best,

    John A. Smaldone

  • Seems to me they are saying our Senior are uneducated and unable to know whats best for them. I don’t see the same happening to forward borrowers. We are talking about people that have paid off there homes & obligations, responsible people. They thought they would live out there lives on penions,investments,SS and as we all have found out thats not happening today and age has nothing to do with it. These people are proud and the last thing we need to do is make them feel they have to beg for help.. I think it might be time for this honest, caring Reverse Mortgage Originator to change careers this saddens me… I’m glad my mother got her reverse mortgage years ago..

  • Question_Mark,rnrnI appreciate your reply and I would not expect everyone to see eye to eye with me all the time, I respect you for saying that.rnIt is imposable to roll the Clock back but their is nothing wrong in using some of the good that was used in the past coupled with the changes time creates.rnThree or four years ago our industry was not looked at or considered predatory or the next sub-prime industry because we were not. In fact we are not now but certain factions and legislators are making us out to be.rnthe proposed bills and some of the new legislation passed has has not only made us less effective than we were but it has also turned us into looking like a greed monger industry like the forward industry has become. Believe you me, we are not that type industry!rnrnYou make a lot of sense in what you say, I enjoyed reading your views on my opinions, many made sense. Please do not think what you might say would be disagreeable to me, on the contrary, I appreciate you for saying what you feel and rncombating my views if you see them differently.rnrnWe are in very troubled times, our industry and most definitely our country. We have no choice other than whether the storm but we can do all we can to fight it when it is wrong for our clients, the seniors. Thank you Question_mark, you have a good weekend.rnrnMy best,rnrnJohn A. Smaldone

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