Subject: File No. S7-14-11
From: Kara L Brace
Affiliation: Grand Rapids Association of Realtors

May 9, 2011

Why would you want to cripple our economy further by forcing an improving Real Estate Market to hit bottom again? It is common sense that the 20% rule will hinder a lot of people who CAN afford a home from buying. And if the fees are going to be so outrageous for anyone not putting 20% down you might as well consider those deals dead as well. Rather than over-correcting a single issue, why not implement some common sense practices that focus on the full picture: credit history, income, job history, and existing debt? In other words, use the borrowers ability to repay the loan as the guide for whether or not the loan is safe