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#1755807 - 11/07/12 01:51 PM Regulatory comment of the day!
RR Joker Offline
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Perusing the HOEPA comments this morning, I noticed one that comments were not being accepted on...I read the first piece of it, and my curiousity piqued. This, coming from a teacher, is pretty darn PRICELESS!

As a public education teacher, your document needs to be shorter in order to get people to actually read it. You cannot make it understandable by EVERYONE who is buying a house--the education levels of the populace are too varied--so aim for the lowest possible level (maybe high school graduate) and compose your document accordingly. Realizing that it is a legal document, I would recommend all references to the Frank-Dodd Act be removed (it's immaterial; home buyers don't care about the name of the act; make them footnotes) and SIMPLIFY the wording (check out the Lemony Snicket books--I'm not kidding). Follow a legal statement with a sentence that clarifies it in layman's terms: "In other words. . . ." I have been dealing with a state office and there's nothing more frustrating than wading through page after page of legalese when you want a simple, straight-forward answer. You're writing this to HELP the person-on-the-street, not prove you can write something for law school--or political science--graduates. Remember the old phrase KISS (Keep It Simple, Stupid). Good luck! Ask some high school teachers or middle school teachers to help you edit the final document.
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#1755810 - 11/07/12 01:52 PM Re: Regulatory comment of the day! RR Joker
A_G Offline
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::like::
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#1755822 - 11/07/12 02:10 PM Re: Regulatory comment of the day! RR Joker
Retired DQ Offline
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Turnpike Exit 10
That is awesome and I agree wholeheartedly!
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#1755841 - 11/07/12 02:29 PM Re: Regulatory comment of the day! RR Joker
Bankbb1, PITA Offline
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The Sovereign State Of Oklahom...
You bought house that you don't have the money to buy. We let you borrow it. You have to pay us back.
The end
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#1755842 - 11/07/12 02:30 PM Re: Regulatory comment of the day! RR Joker
QCL Offline
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laugh laugh

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#1755906 - 11/07/12 03:40 PM Re: Regulatory comment of the day! RR Joker
RR Jen Offline
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Running and riding everywhere ...
LOVE IT!!!
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#1755926 - 11/07/12 03:55 PM Re: Regulatory comment of the day! RR Joker
chenin Offline
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That's great!

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#1755934 - 11/07/12 04:01 PM Re: Regulatory comment of the day! RR Joker
Quadspapa Offline
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Good for the teacher, and I agree.................but, the bureaucrats will never go for it.
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#1755935 - 11/07/12 04:02 PM Re: Regulatory comment of the day! RR Joker
arye23 Offline
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Of course they won't go with it. If the consumer is given disclosures in plain language that anyone with a high school education can understand, examiners and DOJ lawyers won't have any grounds to go after banks for providing complex products that customers can not reasonably understand and be able to avoid harm.... :sarcasm:
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#1755943 - 11/07/12 04:06 PM Re: Regulatory comment of the day! RR Joker
RR Joker Offline
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Ommm...I think the commenter was commenting on the way proposals are written, rather than the end results...

but you are correct...they still manage to complicate the docs unnecessarily (IMO, of course).
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#1755954 - 11/07/12 04:13 PM Re: Regulatory comment of the day! RR Joker
Princess Romeo Offline

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Now if she REALLY wanted to flummox them, she should have written that the document needs to be pedagogically appropriate!
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Regulations are a poor substitute for ethics.
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#1755962 - 11/07/12 04:19 PM Re: Regulatory comment of the day! RR Joker
RR Joker Offline
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::pulls up Merriam-Webster::
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#1756214 - 11/07/12 08:29 PM Re: Regulatory comment of the day! RR Joker
Princess Romeo Offline

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What can I say - I'm a word nerd.
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Regulations are a poor substitute for ethics.
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#1756301 - 11/08/12 06:09 AM Re: Regulatory comment of the day! RR Joker
Princess Romeo Offline

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I should add that "Pedagogic design" is all the rage in the higher circles of academia. It refers to the design and presentation of information in a manner that is effective and appropriate for the recipient. It is something that teachers must consider when teaching their classes.

As an example, a college level textbook on calculus would not be pedagogically appropriate for a second grade math student.

Unless he's Sheldon.















Bazinga!
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Regulations are a poor substitute for ethics.
Just sayin'

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#1756318 - 11/08/12 01:49 PM Re: Regulatory comment of the day! Princess Romeo
RR Joker Offline
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The Swamp
laugh
Love Sheldon! cool
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#1756328 - 11/08/12 01:54 PM Re: Regulatory comment of the day! RR Joker
Skittles Online
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Looking forward to the show tonight! And I picked up the 'Knock Knock Knock Penny (repeat twice)' shirt for my son for Christmas.
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#1756330 - 11/08/12 01:55 PM Re: Regulatory comment of the day! RR Joker
RR Joker Offline
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Tooooo funny. I bet there is a ringtone for that too!
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#1756347 - 11/08/12 02:22 PM Re: Regulatory comment of the day! RR Joker
Pale Rider Offline
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under the Lone Star
sounds a lot like the old term "age appropriate" PR...but this isn't so elitist...
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#1756583 - 11/08/12 09:17 PM Re: Regulatory comment of the day! Pale Rider
Princess Romeo Offline

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Originally Posted By: Pale Rider
sounds a lot like the old term "age appropriate" PR...but this isn't so elitist...


Age appropriate is only part of the issue. Sure, the age of the student has a lot to with how information is presented, but there are other issues such as IQ, prior learning experiences, cultural references, etc.

For most consumer level documents, I believe "8th Grade reading level" is the standard, but these days, I'm not quite sure what that means.

But..., now you have some new terminology to throw around at the next office party.
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Regulations are a poor substitute for ethics.
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#1756588 - 11/08/12 09:19 PM Re: Regulatory comment of the day! Pale Rider
Princess Romeo Offline

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Originally Posted By: Pale Rider
sounds a lot like the old term "age appropriate" PR...but this isn't so elitist...


So I'm guessing in your case that would mean Hieroglyphs?

whistle
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#1756615 - 11/08/12 10:46 PM Re: Regulatory comment of the day! RR Joker
Pale Rider Offline
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under the Lone Star
that may be the appropriate pedagogically designed medium for "us".... smirk
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#1756628 - 11/09/12 12:13 AM Re: Regulatory comment of the day! RR Joker
Princess Romeo Offline

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Well my daughter just got 100% on her Egyptian Hieroglyph translation test. So let me know if you require any assistance.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#1756638 - 11/09/12 03:15 AM Re: Regulatory comment of the day! RR Joker
Rocky P Offline
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Florida
Sample labeling.

1 - This is the note. It says you must pay us the money back with interest.
2 - This is the mortgage. It says if you do not pay us back, we will take your property.
3 - These are the rest of the documents. Most are there because the government thinks (and sometimes rightly so) that you are stupid and don't know what you are doing. Rather than read them, ask an attorney, or a high school english teacher to explain them to you.

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#1756643 - 11/09/12 04:33 AM Re: Regulatory comment of the day! RR Joker
Princess Romeo Offline

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I do hate to say this, but let's face it - the reason we have more and more complicated disclosures is because there is a certain small percentage of lenders that look for ways to rip people off.

And while there is nothing wrong (and plenty of things right) with the idea of an adjustable rate mortgage, what started out as a good idea got twisted into programs that had so many twists and turns and traps that it WOULD take a college level text on calculus to figure it out.

And the justification was "If the doesn't say we can't do this, then we can" regardless if it was ethical or not. And yes, there are a number of borrowers who signed anything because they wanted the house, or they wanted the money out of the house, but there were plenty of people who got tricked, snookered, waylaid, etc. by some very greedy and unethical people.

And all of the pedigogy in the world can't fix that. So hows about a disclosure that fits a plain vanilla straight rate, another for an uncomplicated ARM, and the rest of the loans carry this disclosure in bold 18 font type:

WARNING - THIS LOAN IS VERY COMPLICATED AND CHANCES ARE YOU WON'T UNDERSTAND THE TERMS AND MAY NOT BE ABLE TO PAY IT BACK. PROCEED AT YOUR OWN RISK.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#1756678 - 11/09/12 01:59 PM Re: Regulatory comment of the day! RR Joker
waldensouth Offline
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FINALLY ABOVE the gnat line
Don't forget the contributions lawsuits have made to our loan documents. Promissory notes didn't used to be ginormous with small print. Most of that language is there to protect the bank from a lawsuit.

Face it - when lawyers get their hands on anything, it gets longer and more complicated.
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