Saturday, September 15, 2012
Ben Bernanke says rates will be relatively low through 2015 and this will stimulate job growth and yadda, yadda, yadda ... does this indicate that Ben has looked into his crystal ball. Clearly I am no Ben Bernanke however I find this an interesting posture right before election time. He says the goal is to stimulate i.e. make people spend, buy houses, create jobs ... heck we haven't even recovered from the last real estate crash and 18% of all real estate loans are still delinquent (including the new loans made under the newest and most stringent guidelines-Yes!). We might be able to wave the flag however we are a long way from declaring recovery and going on a drunken sailor spending binge. This tactic normally steers the economy towards spending and not saving. We have more rainy days ahead to deal with ... and then ... what about the inflation that will follow the spending spree ... All of a sudden I hear that song in the background "Things that make you go Huh? Certainly there are great reasons to invest in real estate which I would love to discuss further however this is about Ben so, here's the story released last night ... http://abcnews.go.com/Business/federal-reserve-interest-rates-low-mid-2015/story?id=17226149
Friday, September 14, 2012
It is very apparent that prices hit bottom quite some time ago and are clearly rising, especially here in the Coachella Valley. A tight inventory has made activity (especially in the under $300,000 pricepoint) quite competitive with multiple offers being the norm; and, if you haven't been Pre-approved by your Lender don't bother looking at homes or writing an offer because it's like bringing a knife to a gunfight. If you've not been Pre-approved and start looking at homes, it is inevitable that you are going to run across the house of your dreams and any offer you make is not going to be well received because someone else will have been prepared with a pre-approval so rather than affording yourself the chance of getting into a multiple offer situation with at least a chance to compete for the home, the other Buyer is going to win because they were ready. You can't win the game unless you know all the rules. Anyway, back to pricing ... word is that 18% of exisiting loans are delinquent and that includes the new loans made under the new guidelines so if the economy doesn't improve soon, we could be subjected to another tailspins so stay tuned for more ... here's the story about prices ... Home prices during the first half of 2012 posted their strongest gains in six years, the clearest sign that more U.S. housing markets have hit bottom. Home prices during the first half of 2012 posted their strongest gains in six years, the clearest sign that more U.S. housing markets have hit bottom. But don't confuse that with a full-on recovery. WSJ's Nick Timiraos reports. Photo: Getty Images. . But the housing market remains far from normal. Hitting a bottom shouldn't be confused with a full-on recovery, which looks a ways off. Today's rising prices have less to do with surging demand—though hard-hit markets in Arizona, California, and Florida have seen significant investor appetite for distressed homes—than with declines in the number of properties for sale. Inventories of "existing" homes—that is, ones that haven't just been built—are at eight-year lows. New-home inventories are lower than at any time since the U.S. census began tracking them in 1963. In some cities, there are one-third fewer homes listed for sale than a year ago. Here's why prices are rising: There are more buyers chasing fewer homes, and—critically—fewer distressed homes, such as foreclosures. Low inventory is one sign that housing markets may have reached a turning point because many want to buy at the bottom but few want to sell. There are several factors behind the low inventory. Banks have slowed their pace of foreclosures. Investors have snapped up discounted properties that they can convert into rentals. Home builders, struggling for several years to compete on price with foreclosed properties, have added little in the way of new supply. For now, price gains are concentrated at the low end of the market, where inventory declines have been most dramatic. "The market is really drying up in these seemingly distressed markets really quickly," said Michael Sklarz, president of research firm Collateral Analytics. "They really are scratching for properties to sell." Low inventory is benefiting home builders, as buyers grow frustrated by bidding wars sparked by a shortage of move-in-ready housing. "People can't find inventory that they want, so they say, 'I'm just going to buy the house down the block that's brand new. I don't have to go through the whole torture,' " Mr. Sklarz said. Housing's progress is good news for the economy. Residential investment has now contributed to U.S. economic output for the past five quarters, which hasn't happened since 2005. In other words, housing is no longer a drag, though it is packing far less of a punch than it normally does at this point in the economic cycle. Rising prices also could help turn around consumers' fragile psychology, an unpredictable but important factor that can fuel more sales. But low inventory isn't necessarily a sign of strength. One problem is that many sellers can't or won't become buyers. Millions still owe more than their homes are worth, and even more—about 45% of all homeowners with a mortgage, according to data firm CoreLogic Inc.—have less than 20% in equity. That means they don't have enough money to make a large down payment and pay their real-estate agent's commission to buy a comparable house. Large price declines have left cities without what historically has been the most active segment of the home-buying market: families looking to trade up and retirees seeking to downsize. That leaves many markets relying on investors and first-time buyers, who are most sensitive to rising prices and mortgage rates. Ironically, prices are rising fastest in markets that have the most underwater borrowers because so few homes are for sale. While low inventories have helped firm up prices, they could also soon lead to year-over-year declines in sales volumes because there aren't enough homes on the market to sustain the current sales pace. Consider Phoenix. Home prices through June were up by 17% over the past year, the best increase among the nation's big cities. But home sales in July fell 8% from a year ago, amid a drop in supply of more than 25%, according to a report from Mike Orr of Arizona State University. Jon Mirmelli, a local real-estate investor, said, "Buyers aren't happy with what they see, and they're staying on the sidelines." There are other reasons for caution. Banks are still stingy with credit. Many would-be buyers have too much debt to qualify for a mortgage. A large overhang of distressed mortgages ultimately could drive more homeowners to sell or push banks to accelerate foreclosures. This "shadow inventory" looks as if it won't be dumped on the market in a way that would trigger deep price declines, but it would probably keep a lid on any swift gains. Jobs and wages also aren't growing fast enough to sustain big rises in home prices. Recent gains may be less indicative of a strong recovery and instead point to how prices in some markets "overcorrected," bringing in investors who will step back as prices firm up. Others worry that mortgage rates, which are down by a full percentage point from one year ago, are temporarily boosting sales and that housing demand will slump once rates rise. Compared with a year ago, mortgage rates allow borrowers to take out about 12% more in debt without increasing their monthly payment. The changing debate over housing underscores the sector's tentative progress. Earlier this year, the question was whether housing would hit bottom this year or next. Now, it is "about how strong any recovery will be, how long it will last, and whether it will reach every neighborhood in America," said Glenn Kelman, chief executive of Redfin, a real-estate brokerage. An important test comes later this year. In each of the past three years, prices rose in the summer but gave up all those gains and more in the winter, when sales traditionally slow. This year could be different because the supply of homes isn't piling up. Absent a shock to the economy, housing is on the mend. But it will be a long time before it returns to normal. Keep the faith!!!
Fairly recently this article was written and appeared in the Sacramento Bee website. I think it's a good story and backs up my recent blog comments about timing and if you should refinance at all; it is aso a good reminder to shop not only rates but fees as well. Try to get a good faith estimate from several Lenders and make a spread sheet for yourself and really compare what the cost of the mortgage is ... Please note that it's not all about the interest rate unless you are doing a no fee mortgage and then the rate is all you have t cmpare (A no fee mortgage would lump all the costs into a slightly higher interest rate which some choose because you can write off the interest but rarely the fees associated with a refinance - talk to your CPA about this alternative). Here's the story ... By Claudia Buck email@example.com Published: Sunday, Aug. 26, 2012 - 12:00 am | Page 1D Last Modified: Wednesday, Aug. 29, 2012 - 1:56 pm They're knocking on the lender's door. As mortgage rates have tumbled to all-time lows, demand for refinancing has fired up homeowners nationwide. And it's not just those drowning in underwater mortgages. With rates for 30-year mortgages hovering below 4 percent since last October, all kinds of homeowners are trying to get their monthly mortgages reduced, say lenders and mortgage experts. "It's huge. It's buried our staff and every other lender in town," said O.J. Vallejo, mortgage consultant with First Priority Financial in Sacramento, who said his three-person staff has been working six days a week the last four months. Nationally, refinance volume "has been running at a three-year high in recent weeks, as mortgage rates remained extremely low," Mike Fratantoni, vice president of research for the Washington, D.C.-based National Mortgage Bankers Association, said in an email. "With refinances, the No. 1 driver is interest rates." Along with months of record-breaking low interest rates, other factors are driving the refinancing boom: a competitive lending market and changes in some federal refinancing programs for struggling homeowners. It's prompted many established homeowners with old-school, high-interest mortgages to decide it's time to refi. Neil and Louise Mueller, longtime Land Park residents, were encouraged by their financial planner to look into refinancing their mortgage last spring. "It was almost too easy," said Louise, an American River College counselor, who said the process, including a home appraisal, took about three weeks. The result: Their 30-year, fixed-rate mortgage dropped from 5.12 percent to 3.87 percent, which lowered their monthly payment by about $100. They also pulled out about $11,000 for savings and for a family cruise overseas with their two adult children. Why refi? Generally the primary reasons for refinancing a mortgage are to: • Lower monthly mortgage payments. • Eliminate the unpredictability of an adjustable-rate mortgage by switching to a fixed rate. • Free up home equity cash for home improvements, college costs or other expenses. • Shorten the loan term, say from a 30- to a 15-year mortgage, which can save thousands in interest payments. Saving money is usually the biggest incentive. Calling the low rates "historic," John Winters, a wealth adviser with Morgan Stanley Smith Barney in Sacramento, said he recently advised all his clients to consider a refi. Especially for those "finding it difficult to live with" the anemic returns on low-interest CDs and bonds, freeing up monthly income by refinancing can make sense, he said. Should you refi? It's a personal calculation that varies. Generally, you look at how long you plan to be in your current home and whether the upfront costs outweigh the monthly savings. "If you're not going to be in your home another one or two years, you're not going to recoup the closing costs," said Greg McBride, senior financial analyst with Bankrate.com. "Everybody's situation is different," said mortgage consultant Vallejo. "There's no right or wrong answer. The only answer is what works for your family." Some couples who refinance are looking ahead to retirement. "Paying off the mortgage is now back in vogue," Vallejo said, especially for those in their late 40s or 50s, who want to be mortgage-free at retirement age. That doesn't necessarily mean they'll lower their monthly payment by refinancing. For example, a couple with a $250,000, 30-year loan at 5.25 percent three years ago would have been paying about $1,380 a month. If they refinanced their current balance to a 20-year, 3.5 percent loan today, their payments would increase slightly, to $1,405. "Their payment goes up $25, but they just took seven years off their mortgage," said Vallejo. "That's almost $116,000 in interest. That's huge." On the other hand, younger homeowners with kids might choose a 30-year mortgage when they refinance because they need the lower monthly cash flow to save for college or pay off debt. Or those with adjustable mortgages due to reset to higher rates may want to lock in single-digit rates. What you'll pay The mortgage rate you'll be offered depends on numerous factors, including: your credit score, loan amount, loan-to-value ratio (how much you owe compared to the home's appraised value), length of your loan term and type of home (rates on condos, rentals and vacation homes are typically higher.) Lots of mortgage ads promise "no-cost" loans. According to some lenders, that's a misnomer. "It really means 'no cash out of pocket,' " said Vallejo. "There's no free lunch; somebody is paying for it." Typically, in a no-cost loan, all closing costs and pre-paid items (such as appraisal fees and credit checks) are paid by the lender and built into the interest rate. Shop around It pays to compare quotes from several lenders because they offer different rates and fees. Start with your current lender or sit down with a local loan originator. You can also do refinance comparisons online, using mortgage calculators at sites like Bankrate.com or those of individual banks and lenders. If you're a struggling homeowner, ask your lender about changes in the federal Home Affordable Refinance Program and FHA refinance programs that have made refinancing options more plentiful. Bankrate.com's McBride said the refinance market is particularly "compelling" in California, where home prices have bottomed out and there are lots of competitive lenders. But don't focus solely on interest rates, said McBride. When comparing refinance quotes, look at appraisal fees, title searches and closing costs. And be sure you're comparing the same loan terms, not a 15- and a 30-year, for instance. Good standing Be sure the lender is in good standing. Tom Pool, spokesman for the state Department of Real Estate, said state and federal licensing standards for mortgage originators are much stricter than they used to be, which "has weeded out most of the bad actors." Nevertheless, you can check a company's or individual's licensing status at the state Department of Corporations (www.corp.ca.gov) or the Department of Real Estate (www.dre.ca.gov). Pool also recommends online searches at sites like the Better Business Bureau (necal.bbb.org) to see if the lender has been linked to bad practices or scams. Too late? Even though interest rates have inched upward in the last month, you're probably not too late. "It's not worth losing any sleep over," said Bankrate's McBride. "Given the European debt crisis, (interest rates) can't rise appreciably." On the other hand, the national mortgage bankers group predicts mortgage interest rates will "drift slowly higher" next year, leading to significant declines in refinance activity. Above all, make sure a refinance is right for your situation. "It's a significant financial transaction," said Edward Achtner, an Oakland-based regional sales executive for Bank of America. "If buying a home is the largest transaction a consumer embarks upon, a refinance is a close second. Do the research, evaluate the different options. Take your time and do not be pressured into making any decisions." Editor's note: This story was changed Aug. 29 to correct the length of the Muellers' mortgage. Read more here: http://www.sacbee.com/2012/08/26/4755335/personal-finance-is-a-mortgage.html#storylink=cpy
Thursday, September 13, 2012
My advice is to jump on it while you can because rates won't be here forever ... For Immediate Release: September 10, 2012 Contact: Washington D.C. Office (202) 224-3553 Menendez,Boxer Urge Republicans to Join Them to Help Responsible Homeowners Refinance WASHINGTON, DC - Citing new momentum and support among a broad array of stakeholders, U.S. Senators Robert Menendez (D-NJ) and Barbara Boxer (D-CA) today reintroduced the Responsible Homeowner Refinancing Act and called on Republicans to join them in passing the measure which would help millions of responsible homeowners refinance at lower mortgage rates. “I’ve received thousands of messages from hardworking homeowners back home, including a cancer survivor named Linda who said trying to refinance her mortgage is harder than fighting cancer,” said Senator Menendez. “Passing this bill will get rid of the red tape that leaves millions of borrowers like Linda trapped in higher interest loans, put money back into the pockets of middle class families and strengthen our economy. I’m asking Republicans to join us in putting families first.” Senator Boxer said, “This bill is a win-win-win: homeowners will have more money in their pockets, Fannie and Freddie will see fewer foreclosures, and the housing market and economy will be strengthened. That’s why the Menendez-Boxer bill has such broad support from industry and consumer groups.” The legislation is supported by a broad array of stakeholders representing borrowers, lenders, sellers, finance and industry, and other experts including the Mortgage Bankers Association, National Association of Realtors, National Association of Home Builders and the Center for Responsible Lending. Summary of The Responsible Homeowner Refinancing Act of 2012 Senators Robert Menendez (D-NJ) and Barbara Boxer (D-CA) There are nearly 13.5 million responsible borrowers in loans guaranteed by Fannie Mae and Freddie Mac who could benefit from refinancing at today’s low interest rates. Although recent changes to the Home Affordable Refinance Program (HARP) were a step in the right direction, they left in place barriers that will keep millions of borrowers trapped in higher interest loans. The Responsible Homeowner Refinancing Act will build on these changes and further expand opportunities to access historically low interest rates for borrowers who make their mortgage payments on time. To remove the barriers preventing borrowers who are making their payments on time from refinancing their loans at the lowest rates possible, the bill would: • Remove barriers to competition Under HARP, lenders who want to compete with the borrower’s current lender for that borrowers’ business continue to face stricter underwriting criteria and greater risk that the GSEs will force them to buy that loan back should the borrower default. These different standards have posed a barrier to competition, resulting in higher prices and less favorable terms for borrowers. A recent study by Amherst Securities Group found that HARP borrowers are paying more than half a percentage point more than borrowers with other types of loans. This bill would direct the GSEs to require the same streamlined underwriting and associated representations and warranties for new servicers as they do for current servicers, leveling the playing field and unlocking competition between banks for borrowers’ business. • Guarantee equal access to streamlined refinancing for all GSE borrower When FHFA recently expanded HARP eligibility to underwater borrowers, they continued to require lenders to distinguish between borrowers with less than 20 percent equity and greater than 20 percent equity in ways that left higher equity borrowers with greater costs and administrative burden. This meant that borrowers who have been paying down their mortgages over many years, building equity in their homes, were locked out of the program. This bill would ensure that all GSE borrowers who are making their payments have the same access to simple, low-cost refinances, regardless of the level of equity they have in their home. This is not only a simple matter of fairness- it also makes good business sense. Providing a single set of rules for all lenders and all GSE borrowers will simplify the process for all involved, allowing all lenders to offer a single, streamlined program to all GSE borrowers who have been paying their loans on time. • Eliminate up-front fees completely on refinances Although the GSEs lowered up-front fees for HARP loans with less than 20 percent equity, they left them in place for those with more equity. This created the economically indefensible situation in which borrowers with significant equity in their homes could face steeper costs in refinancing than borrowers with no equity whatsoever. So borrowers who pose less risk to the GSEs are in fact paying a higher risk premium. These additional fees can be as high as two percent of the loan amount, or an extra $4,000 on a $200,000 loan. For borrowers struggling to keep up with their payments, this is an additional cost they simply cannot afford. This bill prohibits the GSEs from charging up-front fees to refinance any loan they already guarantee, which is also in the best financial interests of the GSE’s and taxpayers. • Eliminate appraisal costs for all borrowers GSEs use Automated Valuation Models to determine home values without the need for slow and costly manual appraisals. However, borrowers who happen to live in communities without a significant number of recent home sales often cannot use these models and are forced instead to pay hundreds of dollars for a manual appraisal for a HARP refinance. This bill requires the GSEs to develop additional streamlined alternatives to manual appraisals, eliminating a significant barrier and reducing cost and time for borrowers and lenders alike, especially in rural areas. Again, this just makes good economic sense. Taxpayers are already on the hook for these loans and will benefit from providing the borrowers with an easier path to refinancing. • Further streamline refinancing application process HARP already restricts participation to borrowers who are current on their loans and have demonstrated a commitment to making their payments on time – even in the face of loss of income or employment. There is thus no reason to require proof of employment or income for these loans, particularly given that the GSEs already retain the risk, and that risk will only go down with lower interest rates. So this bill eliminates employment and income verification requirements, further streamlining the refinancing process and removing unnecessary costs and hassle for lenders and borrowers alike. • Save taxpayers money According to the CBO, the bill pays for itself through reduced default rates on GSE loans, which saves taxpayers. http://boxer.senate.gov/en/press/releases/091012.cfm
Monday, September 10, 2012
Well, it seems that it's time for the Adjustable Rate Mortgage conversation again ... Some people forget that while lax approval guidelines and bad lending practices were at the core of the financing debacle our economy went through, once the apple was cut open, there also lay the Adjustable Rate Mortgage "ARM". While it is not an evil financing vehicle by any means, it can tempt many away from the 'sleep good' insurance of a fixed interest rate. It definitely can be a great tool for purchases or refinances whose owners will not be in the property for a lengthy period, i.e. those who might downsize when kids go off to college or anticipate an employment tranfer or even those anticipating paying off their mortgage debt in the near future. Regardless of the reason, in my opinion, if anyone discuses ARM's with you ... you should be thinking short term solely and if you do choose one you should at least double your time estimate to give yourself a cushion if your plans change. Thinking one year take the 3 year ARM. Thinking 2 years ... go for the 5 year.Read on for one person's opinion about big savings and then think about that 'sleep good' insurance When an adjustable-rate mortgage makes sense from August 30, 2012: 5:00 AM ET Locking in a historically low fixed rate might feel safer. But borrowers can save big on ARMs right now. By Janice Revell, contributor FORTUNE -- During the housing meltdown, adjustable-rate mortgages were vilified as a hallmark of irresponsible borrowing. Recently, though, they've been making a comeback, especially among affluent borrowers. This summer, for instance, Facebook (FB) CEO Mark Zuckerberg reportedly financed his home using an ARM with a rate of just 1.05%. Most borrowers can't snag a rate remotely close to that. But many would still do well to consider an ARM right now -- even if conventional wisdom says otherwise. An adjustable-rate mortgage offers an introductory period in which you pay a lower interest rate than with a fixed loan; after that, the rate can fluctuate up or down. With rates near historic lows, the safety of locking in a fixed rate appeals to many borrowers. But they're paying a premium for that security: The spread between rates on 30-year fixed-rate mortgages and the most popular ARMs now stands at about one percentage point, more than double the difference just five years ago. That means that homeowners who are planning to either move or pay off their mortgage over the next few years can save big with an ARM. Take, for example, a homebuyer who plans to pay down an $800,000 mortgage. Currently the rate on the fixed portion of a 5/1 ARM -- which is guaranteed for the first five years and adjustable once a year thereafter -- is around 3%. In a typical 5/1 ARM, the maximum increase during the sixth year is five percentage points above the initial rate. Alternatively, our hypothetical borrower could opt for a 30-year mortgage that locks in an annual rate of about 4%. MORE: Mortgage applications up, mortgages not so much Fortune asked Greg McBride, an analyst with mortgage tracker Bankrate.com, to run the numbers on both options. To be conservative, McBride assumed the worst-case scenario with the ARM -- one in which the rate shoots up to the 8% maximum in year six. Here's what would happen: For the first five years, our homebuyer's monthly payments on the ARM would be $3,373 -- or $446 less than what he'd pay under the 30-year fixed mortgage. Over that period he'd save a total of $39,000 in interest and would amass $12,000 more in equity. After the initial five years the monthly payments under the ARM would balloon to $5,490. But it's not until the seventh year of the loan that the savings garnered by the lower ARM payments during the first five years would be wiped out entirely. (This doesn't factor in the mortgage-interest tax deduction, which would be greater on the fixed-rate loan for the first few years but higher on the ARM thereafter.) If after five years, however, the rate on the ARM increased at a more moderate pace of one percentage point a year, the initial savings wouldn't be eclipsed by the fixed rate until the 10th year of the loan. The bottom line: Unless you definitely plan to stay in your mortgage over the long term, it might pay to adjust your thinking. * * * As always ... Keep the faith and when making decisions like these, don't just talk to your Lender and Realtor, choose to consult your CPA or Estate Planner for major decisions like these.
The Dept. of Justice Consumer Protection Branch is warning consumers about debt relief scams and providing tips to avoid such scams. Tips include: •Fraudulent debt relief companies will often make claims of being able to negotiate a one-time settlement with creditors that will reduce a consumer’s principal by 50 percent or more. The Consumer Federation of America, an association of non-profit consumer organizations, warns that such a promise is a virtual impossibility. •If you have trouble making credit card payments, immediately call the creditor to work out a payment plan. If that is unsuccessful, a non-profit credit counseling service may be able to help you. These services may charge a small fee, but the cost will be substantially less than using a debt relief company. An excellent resource for locating a local credit counseling service is the National Foundation for Credit Counseling, at www.nfcc.org. •If a company offers a “one size fits all” solution, what they are really offering is a “no size fits anyone” problem. Legitimate credit counseling services tailor a consolidation plan to each consumer’s individual needs. •Do not be afraid to ask questions. Demand that the company disclose set-up and maintenance fees, and that these fees be set in writing. According to the Consumer Federation of America, consumers should not pay more than $50 for the set-up fee and $25 for monthly maintenance of the account. •Do not rely on the company’s website. Conduct your own research of the company – the Better Business Bureau and the state consumer protection agencies are valuable resources. For more information on debt relief scams, see the Federal Trade Commission’s website. Additional information on legitimate debt relief services can be found on the Consumer Federation of America’s website. As always - keep the faith!
No-fee mortgage option is on the way ... Richard Cordray, who runs the consumer bureau, announced new rules Friday that would limit fees on mortgages. NEW YORK (CNNMoney) -- Lenders would have to offer potential home buyers an option to get mortgages with no fees, under a rule proposed by the Consumer Financial Protection Bureau. Generally, homeowners pay fees and points in exchange for lower overall interest rates on mortgage loans. "Consumers have a hard time comparing loans when they are dealing with a bewildering array of points and fees," said Richard Cordray, director of the Consumer Financial Protection Bureau, in a statement. "We want to provide consumers with clearer options and enable them to choose the loan that they believe is right for them." In the Dodd-Frank Act, Congress wanted to clean up the process of getting a residential mortgage, which was criticized as a contributing factor to the financial crisis. The idea was to ensure consumers understand the mortgage loans they're offered, as well as all the accompanying fees. While good news for consumers, the mortgage proposal is actually easier on lenders. Lawmakers banned extra fees and points on mortgage loans in cases when the originator makes a commission -- which happens with most mortgages. Under this proposed rule, the bureau would allow lenders to keep offering consumers options to reduce their mortgage interest through fees and points, as long as those fees and points actually reduce the overall interest rate on the mortgage. Lenders must offer the no-fee mortgages as well. A senior official with the consumer bureau explained that the rule was a balance between a blanket ban on fees and the current origination process, which has no rules for mortgage fees. Consumer groups and those in the lending industry weighed in, saying it would be better to keep giving consumers the opportunity to lower interest rates by paying more up front. The bureau will now collect comment on the rules and finalize them to take effect by January.