Posted by David Butler on February 21, 2010 at 14:25:10:
In Reply to: David... posted by acw on February 21, 2010 at 09:30:16:
Hello acw,
You are very welcome... thanks much for your interest and participation.
We do need to do everything we can to get the language in the rules clarified, and hopefully in the direction of common sense as opposed to allowing another well-intentioned law cause unintended consequences by creating a problem where none previously existed.
This is particularly so for those CREI who specialize in doing "Subject To" and/or "wrapped contract" transactions. Some less scrupulous practitioners may need to be regulated, no question about that... but not through the means of blanket licensing requirements. Especially when such licensing is generally onerous, for all but those who regularly conduct true mortgage lending brokering - as opposed to one offering seller-financing on his own nonowner-occupied residential properties.
The instructions for how to post your comments are found in several different posts by various folks, including at the bottom of my post at:
CALL TO ACTION Redux - KILL (HUD) BILL Vol. 2
http://www.creonline.com/wwwboard/messages/90142.html (Real Estate Discussion Forum)For everyone's convenience, I am reposting those instructions immediately below in this post. BTW... they are easier to follow than the look to be at first glance. I went through the same process after finding these instructions in an earlier post on the topic, made by Chris. Follow these simple steps:
1. Logon to www.regulations.gov You will see two white boxes for searching
2. On the left box labeled "Document Type", pull the menu down and select "proposed rules"
3. On the right box labeled "Enter keyword or ID", enter "safe mortgage". Then, press search
4. Locate the blue search result "FR-5271-P-01 Safe Mortgage Licensing Act: HUD Responsibilities Under ...." To read the rules, click on this title. You will be taken to another page. You will see "views". You can click on PDF file or another symbol which will show you the rule document online.
5. On the right of the screen, click on "submit comment"
6. Complete the form providing required information and your comments and then submitThanks again for your participation in this effort!
Saving Our Economy... One Property At A Time!
Nascent Equity &
Hotspur Investment Group
David P. Butler