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?