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#121983 - 10/10/03 06:18 PM Power of Comments to Regulators
SJB Offline
Diamond Poster
Joined: Jun 2002
Posts: 1,210
This week the OTS finalized its transactions with affiliates (TWA) regulations which implement Regulation W, with some OTS-specific changes.
One difference between OTS regs and all other bank regs on TWA was that OTS had a "one-way control" provision that made many more companies affiliates of thrifts than would be for banks. ONE COMMENTER suggested that the OTS should conform its control provisions to those found in Reg W so banks and thrifts would all operate under the same control concepts for purposes of TWA. The OTS changed its control provisions as suggested by that one commenter.
I know we like to complain about our regulators but I think this points out two very important points: one, they do listen, and two, comments do count (as Andy and others have said before.)
My opinions are not legal advice and are worth what you paid for them.

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General Discussion
#121984 - 10/10/03 06:36 PM Re: Power of Comments to Regulators
Suwannee Offline
Platinum Poster
Joined: Jun 2002
Posts: 641
Absolutely comments count!! Several years ago HUD was trying to change the due date for HMDA reporting from March 1 of each year to February 1 of each year. Due to the comments received, they did not make this change. That was the first comment letter I have ever sent in. When I saw that the power of comment letters worked, it encouraged me to send them in when I thought the proposal would affect either my institution or an institution that I might consider working for in the future.

Look at the RESPA proposal that came out in July 2002. There were so many comments received (45,000+, mostly negative)on that proposal that HUD has been taking a serious look at it to see how they can make it better based on the comments and the needs of the public.

I encourage all lenders, brokers, realtors, banks, the public, etc, to send in comments when the agencies ask for them. How are they supposed to know how these proposals will affect us if we don't tell them?

When you lose, don't lose the lesson.

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#121985 - 10/10/03 07:37 PM Re: Power of Comments to Regulators
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
And yet we still sit and wait for the "New" New CRA to be decided on. Perhaps too many comments went in. They just can't seem to figure something out!
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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