Due June 12^th^ 2008

Docket ID: HUD-2008-0028

Docket Title: FR-5180-P-01

From: David Fahrmann, MN Lending Co. 612-998-1455 6465 Wayzata Blvd,
Suite #300, St Louis Park, MN 55426. Office: 952-960-9600

To whom it may concern:

There are good bad changes recommended. Strangely, most of the changes
are impossible and or would kill competition and raise prices for
everyone.

1\. YSP.

By forcing brokers to show YSP as part of the origination fee, you are
essentially going to kill the brokers and the competition that we
provide. When I first got into this business 6 years ago I could beat
the banks by a half percent. The consumer could save this money AND I
could make YSP. If I worked at the bank, I'd make half as much and all
the profits would go to big business.

In other words, YSP IS NOT BAD. It's just the profit going to small
business instead of large business. If I'm beating the competition
(banks) with similar to slightly higher fees but I'm getting them a
better rate, then a competitive market place is doing its job. Consumers
are saving money!

Due to the competition that brokers have provided, all banks have had to
be more competitive and lower their rates to be close to ours.
Currently, I can usually only beat the banks by about one eighth of a
percent. If I have to show YSP in the origination fee, I can assure you
that most people will use the bank and ultimately wipe us out.

If you wipe us out, the banks can charge higher rates and no one will
know because we aren't alive to show the consumer a better rate! More
importantly you need to know that BANKS SET THE RATES, and they can hide
their profits no matter what rules you pass. Will the banks share the
profit with their workers? NO. They will take it all for themselves. Why
not allow us small brokers a chance to have a life outside of a
mega-bank call center and make a livable wage?

2\. Locking rates and fees for 10 days is not possible and will increase
fees rates for everyone.

Why? Because banks rates are changing at least daily and more recently
numerous times each day. In other words, the only way to guarantee a
rate would be to bid high and pray it doesn't go above that rate. This
raises rates for and fees for everyone and turns mortgage brokers and
banks into gambling institutions. I can assure you, I don't make enough
money to lose money on a deal. It's taken me 6 years to make enough
money so that I'm not borrowing money to make ends meet!

Here is how I win most of my business: When the customer is ready to
lock, I will look at all the banks that fit the parameters of my
customer. Since the banks offer us wholesale rates and COMPETE for my
business, the cheapest bank one day is not the cheapest bank the next
day. In other words, competition is working! I then quote the customer a
rate. They may or may not decide to lock. If they want to shop, then we
wait for him to get other quotes from other lenders. Ultimately, who
ever has the lowest rate (assuming fees are comparable) will win. YSP is
not and never has to be part of this equation! I usually win because I'm
willing to make less money than my competitors. However, I could never
guarantee a rate or fees will be the same the next day or even the next
hour!

3\. GFE and the HUD1 the same.

This would be great. It would cut down on a lot of confusion and help
the customers see that the fees have not changed since they were
originally quoted. It would also help the broker compete with banks on a
line by line basis....but NOT if you are requiring us to show YSP! The
customer will be confused and go with the bank even if we are the better
deal.

4\. Make brokers guarantee fees.

This would be OK IF you made everyone if the process guarantee fees so
that we could quote directly from the source and know that nothing would
change. However, that is literally impossible because there are changes
that occur in the process and there is no way to guarantee the fees
UNLESS you over bid everything and then come down from there. Edina
Realty of MN has tried a "fixed fee" option and it failed; nobody wanted
it. Why? The only way to fix it is to RAISE prices!

This also reduces competition between banks. Each bank has their own
fees. If I need to switch to a cheaper bank with higher fees, why should
I eat that cost?

5\. Closing Script summarizing the loan.

This seems like a good idea to let the customers know exactly what they
are getting in a summarized form.

6\. Increasing RESPA rules and regulation.

While this my appear to be helping the consumer, you are really just
going to increase costs and confusion for everyone; ultimately killing
the small business broker and letting the banks make all the money.
Brokers are not the bad guys! If you eliminated BAD/Dangerous loan
programs, you wouldn't need all this regulation. The market is already
taking care of this by eliminating most dangerous products such as the
Option Arm (illegal in MN) and most sub-prime mortgages are gone.

In summary, if you make the brokers show YSP, you will kill us off and
the consumer will pay more for all services going forward.

If you really want to clean up the industry, force everyone to use the
same GFE for competitive estimates and get rid of dangerous loan
programs.

Provide a summary page that describes the loan that can be used in the
initial competition so the customer is sure that they are getting a safe
loan.

Don't force thousands of people like me to work a the big banks!

Sincerely, David Fahrmann 612-998-1455

Loan Officer, MN Lending Co.