No. of Recommendations: 1
CCinOC: "There ain't no Agency lenders who are "phasing out" of anything. They're all hewing as precisely as they can determine to the Dodd-Frank Act."

And I quoted the Dodd-Frank Act.

‘‘(3) PHASED-OUT PENALTIES ON QUALIFIED MORTGAGES.— A qualified mortgage (as defined in subsection (b)(2)) may not contain terms under which a consumer must pay a prepayment penalty for paying all or part of the principal after the loan is consummated in excess of the following limitations:

‘‘(A) During the 1-year period beginning on the date the loan is consummated, the prepayment penalty shall not exceed an amount equal to 3 percent of the outstanding balance on the loan.

‘‘(B) During the 1-year period beginning after the period described in subparagraph (A), the prepayment penalty shall not exceed an amount equal to 2 percent of the outstanding balance on the loan.

‘‘(C) During the 1-year period beginning after the 1- year period described in subparagraph (B), the prepayment penalty shall not exceed an amount equal to 1 percent of the outstanding balance on the loan.

‘‘(D) After the end of the 3-year period beginning on the date the loan is consummated, no prepayment penalty may be imposed on a qualified mortgage.

See post 126607. "Phased-Out Penalties" language is part of the Dod-Frank Act. I never said anything about lender's compliance.

If you do not like the "phase-out" language, take it up with Messrs. Dodd and Frank.

As I previously wrote, not all prepayment penalties are verboten under Dodd-Frank.

Regards, JAFO
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