**MortgageSource, LLC**, Peter J Park (PB), 1441 Kapiolani Blvd Ste
2010, Honolulu, HI 96814

Re: Docket No. FR--5180--P--01

The new HUD Rule is out of touch with the reality as it makes
distinctions among mortgage originators with no basis for doing so. 
Exhaustive studies of mortgage disclosures by the Federal Trade
Commission show that additional disclosures of mortgage broker
compensation created confusion, caused consumers to choose more
expensive loans, led to a bias against broker-assisted transactions, and
impeded competition, thus hurting consumers.

First of all, in today's mortgage market there is little difference
between mortgage brokers and mortgage bankers.

-   The distinctions between brokers and lenders have blurred in recent
    years as lenders themselves typically package and resell loans they
    originate.

-   Consumers are largely unable to distinguish between brokers and
    lenders, which have similar names, use similar signage, and rely on
    similar advertising.

-   Consumers should not have to figure out these differences because
    everyone is competing directly.

-   Automation has also helped to blur the distinctions between brokers
    and lenders.  Most of the industry uses the same computer software,
    so the reality is that the difference between a broker transactions
    and a lender transaction is merely a key stroke on a computer!

-   If applicable and you are doing both broker and lender transactions
    please elaborate on how you are able to function in this manner. 
    Discuss how you can act in multiple capacities and how it can be
    confusing to consumers because you can do both, yet the disclosures
    are different.

Secondly, requiring broker transactions, but not other loan originator
transactions, to make compensation disclosures on the Good Faith
Estimate (GFE) inhibits competition, is unfair to small business
mortgage brokers, limits consumer choice, confuses consumers, increases
prices, and hurts borrowers. In order to promote comparison shopping
there should be a corresponding requirement for lenders to disclose
compensation paid to their own sales staff. Fees similar to the YSP are
present in any mortgage origination distribution channel, regardless of
whether a broker is involved.  Requiring brokers, but not other loan
originators, to make compensation disclosures enables the brokers'
competitors to steer consumers away from brokers, even if brokers offer
more favorable loans.

Moreover, the proposed GFE form misleads consumers by perpetuating the
fallacy that through a lender a zero-point/zero-cost loan is free to the
consumer.  The GFE should treat all originator transactions the same. I
supports making the GFE form mandatory.  However even with this
necessary change, the proposed GFE continues to make a distinction
between broker transactions and lender transactions, which as stated
above hurts borrowers. I also agree that\
the GFE should look like the HUD-1.  The proposed changes to reorganize
the HUD-1 with numbers and names that correspond to the GFE is a step in
the right direction, but not enough to aid consumers. 

Furthermore, I support the change in the definition of "required use." 
The new definition still allows for package bundling (an optional
combination of bona fide settlement services at a discount rate); so
long as consumers receive a better deal then if they purchased
settlement services separately. However, we need to avoid any brightline
test that sets a dollar amount higher than zero as a threshold for
determining what constitutes an economic incentive or disincentive.  The
threshold for determining incentives and disincentives should be "any
thing of value."  HUD should not consider the RESPRO bright-line test,
which sets a dollar amount threshold for determining economic incentives
/ disincentives.

As proposed, the current GFE will allow loan officers at lender's to
continue to sell against mortgage brokers by pointing out YSP and not
disclosing that they too receive indirect compensation.  Should HUD
implement the proposed GFE, this practice by lender loan officers should
be considered by rule as a deceptive trade practice.  The FTC should
have enforcement authority to prevent this scenario.