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CAMP needs your voice! We would like to hear the opinions of CAMP members on what matters most to you in regards to CAMP’s Government Affairs positions. Your Government Affairs leadership team has created a series of surveys to gather your insight. Please take a moment to complete this survey to give us your input on current legislation and regulations that affect you directly.

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* 1. Dr. Elizabeth Warren, Assistant to the President and Special Advisor to the Treasury Secretary, is working on combining and simplifying the disclosures required under the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA). Please rank, by order of priority (1 = highest priority), the top three goals that CAMP should fight for as new disclosures are created. Use each ranking priority only once on the following options.

  1 = Highest Priority 2 3
Ensure Forms Do Not Slow the Process
Improve Clarity So Consumers Can Make Informed Decisions
Provide Opportunity for Corrections by Loan Originators in Certain Circumstances
Ensure Forms Do Not Add Costs for Consumers
Ensure Level Playing Field for All Originators
Perform Consumer Testing Prior to Adoption of New Forms to Avoid Unintended Consequences
Reduce Consumer Confusion

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* 2. On Thursday, October 28, the Federal Reserve published an Interim Final Rule on appraisal independence. According to the Fed, the Rule’s new requirements for appraisal independence are designed to ensure that real estate appraisals used to support creditors’ underwriting decisions are based on the appraiser’s independent professional judgment, free of any influence or pressure that may be exerted by parties that have an interest in the transaction. The Fed is accepting comments on the Interim Final Rule and CAMP plans to weigh in. Please rank, by order of priority (1=highest priority), the top three comments CAMP should make about Fed’s Interim Rule on appraisal independence. Use each ranking priority only once on the following options.

  1 = Highest Priority 2 3
Call for the Interim Final Rule to only allow consumers to be charged bona fide appraisal fees that can be substantiated and require disclosure of such fees.
Loan originators who order an appraisal should be required to certify in writing that they did not engage in any act or practice that violates appraisal independence.
Commend the Interim Final Rule for allowing mortgage brokers to order appraisals and reiterate the importance of this for the entire industry, including the GSEs.
The Final Interim Regulations should allow for appraisal portability, which will keep costs down for the consumer as it will eliminate the need for consumers to purchase additional appraisals from each lender if they are shopping for the best mortgage product for their circumstances.
Strengthen the conflict of interest requirements to prohibit anyone from profiting from the appraisal process outside of the appraiser, including earning commissions for ordering appraisals.
To ensure those who order appraisals are not violating appraisal independence rules, the Interim Final Regulations should require National Mortgage Licensing System (NMLS) numbers to be listed on appraisal reports.

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* 3. A number of federal programs have been established to prevent further increases in foreclosures and help more families preserve homeownership. In addition, several states, localities, and private companies have initiated foreclosure prevention efforts. CAMP members can provide unique insights into mitigating foreclosures. It is our belief that addressing these issues on the front end saves money on the back end. Please rank, by order of priority, the top three positions you feel CAMP should take on federal efforts to address the foreclosure crisis. Use each ranking priority only once on the following options.

  1 = Highest Priority 2 3
The federal government should prioritize housing counseling, particularly from entities that provide in-person, one-on-one housing counseling services, for those at risk of foreclosure.
CAMP is considering proposing a program where lenders allow any consumer that is current on their mortgage payments to refinance at today’s lower fixed mortgage rates. No appraisal and no further income documentation would be required for these streamline refinances unless the new payment is higher than the current payment by a certain amount (ex. ten percent). Freddie Mac, Fannie Mae and Ginnie Mae would be required to buy and securitize these mortgages. All origination channels will be asked to process these mortgages.
For underwater borrowers, CAMP is currently considering the federal government should set up a program where lenders evenly split the difference that exceeds the property value between the mortgage holder and consumer. The current mortgage holder would be required to forgive their portion of the difference. The consumer’s amount would remain as a lien against the property with no additional interest owed by the consumer on these funds. This amount would be due and payable at the time of sale, or any subsequent refinance or at maturity. Freddie Mac, Fannie Mae and Ginnie Mae would be required to buy and securitize these mortgages. All origination channels will be asked to process these mortgages.
The federal government should set up a program where lenders remove part of the principal owed from the portion of the loan balance that is subject to interest, thereby lowering borrowers’ monthly payments by reducing the amount of interest owed. The portion of the principal that is subject to forbearance would be repaid by the borrower in full after the interest-bearing part of the loan is paid off or when the home is sold.
The federal government should focus on creating jobs and improving the economy so people can make their mortgage payments and home values can rise.
The federal government should review current foreclosure prevention programs to make sure they are effective and efficient. If they are not, the programs should be changed or eliminated.

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* 4. Please rank, by order of priority (1=highest priority), the top three federal issues that you are currently concerned about. Use each ranking priority only once on the following options.

  1 = Highest Priority 2 3
Appraisal Independence rules to replace HVCC
Federal policies regarding loan modifications/Short Sales
Merging of TILA and RESPA disclosures
Changes to the FHA program
Loan Originator Compensation
Loan Limits

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