Comment: In place of prohibiting Name We loans away from carrying a 3rd lien updates, the final code should need you to definitely a subject We loan need precedence over almost every other liens provided meanwhile
HUD Response. HUD will not agree totally that almost every other regulating requirements result in the a couple of-group disbursement procedures unnecessary. HUD thinks the a couple-group disbursement strategies deliver additional protections maybe not afforded from the such other standards. Including, two-team disbursements will make sure a loan continues are not released facing the new borrower’s wants, and can make it possible to on time aware the lending company so you can disputes between new debtor while the specialist. Appropriately, HUD keeps chose to embrace the new advised dual disbursement criteria rather than transform.
Comment: Help for a couple of-team disbursements. A couple commenters supported the fresh new recommended twin disbursement requirements. The brand new commenters authored your suggestion are reasonable and may avoid the latest disbursal out-of financing proceeds contrary to the borrower’s wants.