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From: Subject: Comments: National Notary Association, Connie Holmes Regulation Z Truth in Lending Public Comments on Regulation Z; Truth in Lending: Title: Regulation Z; Truth in Lending FR Document

It's really the form itself, not the words on it, that needs to change. But I don't like the new text on the forms that says the form can be withdrawn after 60 days. I'd love it if the 90-day grace period was removed from the form. In fact, I'd also love the cancellation fees dropped to whatever they used to cost: 5% of the loan amount. But my real issue with the form (aside from the fact that it's not perfect) is that it creates a false assumption about the borrower. It's not that you have to approve their creditworthiness before approving the loan. That's the old process. The assumption that a borrower is unqualified is based on their credit history. The assumption that a borrower is qualified based on their credit history is based on their credit score — a composite number of all their available credit. But if you approve a borrower even if the borrower's credit has been flagged by something you've done (which it shouldn't if it's a new application), that's an automatic approval. You won't have to check the borrower's credit history. Or have them go to an attorney. Or have to make sure they've made all the required disclosures (if required). Just approve them with the simple thumbs-up that the form says they've satisfied all its requirements. And if they want to switch their terms, they can do that and if the loan is denied, there's no way to prove that they weren't actually eligible for the loan. So, I'd appreciate it if you'd drop the 90-day grace period and put a time limit on when you can withdraw the form. That is, at least 60 days have passed since you received the form, so there's no need to make sure the borrower hasn't made a late payment to get the grace period longer. What else would you change about the form or the grace period? (I'm not including any proposed rule changes in this question because I don't want to suggest that either of these would be good solutions.) If you like, you can drop whatever comment you like here. But you really can't make a substantial comment. I think there are some things on the form that aren't necessary, and it's more effective just to drop one of those and not the other. Or to let me know if you have some ideas, and we can work out something.

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