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smoothlid
429 Posts |
 Posted - 03/31/2008 : 1:24:44 PM
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FYI, hot off the press....
Broker Compensation Disclosure
Due to numerous state laws and regulations, as well as possible federal regulations including proposed amendments to HOEPA and RESPA, GB Mortgage will require a broker compensation disclosure effective with all first mortgage applications received on or after April 1, 2008. Broker compensation must be clearly disclosed to the borrower on or before the date that a loan application is submitted to GB Mortgage.
This disclosure must be in writing and signed by both the broker and the borrower (an original is not required). The total amount of compensation received by the broker may not exceed the amount disclosed to the borrower on this form. You can view a sample form by clicking here. However, you are not required to use our example. Other versions of broker compensation disclosure forms will be accepted, as long as they meet our disclosure requirements. A GFE will not be acceptable, all compensation from all sources must be clearly disclosed as a specific dollar amount on a single, separate document.
Please contact your Account Executive for additional information.
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RGK2394
1245 Posts |
Posted - 03/31/2008 : 1:27:13 PM
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| I guess I don't understand how disclosing exactly how much I will be paid will prevent someone from falling into FC, etc. If they are happy with the rate, the terms, and the fees charged, how will telling them what I make do anything other than get them to try and nickel and dime everyone..? |
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smoothlid
429 Posts |
Posted - 03/31/2008 : 1:31:23 PM
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We don't use them, just signed up with them.
In fact, I bank @ 95% of my deals right thru Freedom.
We like it that way.
Soooooooooooooooooo Glad I don't have to deal with that on a daily basis. |
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servicefirst
3421 Posts |
Posted - 03/31/2008 : 3:31:39 PM
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| They were doing this back in 2001 when I used to use them a lot. Never found it to be a big deal or a deal-killer. |
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americanheartlan
2237 Posts |
Posted - 03/31/2008 : 3:34:42 PM
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| Plenty of lenders are doing this now...including Citi & Wells |
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Boulderco
1298 Posts |
Posted - 03/31/2008 : 7:18:24 PM
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| It's state law in Colorado now and a more and more lenders are requiring it so you might want to get used to it. |
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Chris Clark
5966 Posts |
Posted - 03/31/2008 : 7:19:58 PM
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| RESPA already calls for this type of disclosure. It's just not being enforced- yet. HUD is already working on clarification to force this type of disclosure or be fined... |
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hherrm
1407 Posts |
Posted - 03/31/2008 : 7:34:20 PM
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I already disclose my fee's, never had a problem with it. Now I just have to write it in 3D, so what.
The problem I have is with keeping the same fees as originally disclosed (hope I'm understanding this right)
For example: last Thursday I took an app and disclosed 6.25% with 0.780 yield (best I could find that day) Today, I found in a very small window before rates adjusted 5.875% with 1.7 yield and locked it. The buyer send me kisses through the phone when I told him about the new rate.
Question: With the new law, do I have to credit him back everything over the original 0.780 I originally disclosed? Or does a new disclosure overwrite the old one? |
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808
2870 Posts |
Posted - 03/31/2008 : 8:26:16 PM
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quote:
Originally posted by hherrm
I already disclose my fee's, never had a problem with it. Now I just have to write it in 3D, so what.
The problem I have is with keeping the same fees as originally disclosed (hope I'm understanding this right)
For example: last Thursday I took an app and disclosed 6.25% with 0.780 yield (best I could find that day) Today, I found in a very small window before rates adjusted 5.875% with 1.7 yield and locked it. The buyer send me kisses through the phone when I told him about the new rate.
Question: With the new law, do I have to credit him back everything over the original 0.780 I originally disclosed? Or does a new disclosure overwrite the old one?
Here's how it works in FL, effective 10/01/2007
all matireal changes in loan terms must be provided to and accepted by borrower within 3 business days of terms change but not less than 3 business days prior to closing |
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barrington79
176 Posts |
Posted - 03/31/2008 : 8:31:42 PM
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| So what's the big deal? This is what we're supposed to be doing. |
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VVance
2519 Posts |
Posted - 03/31/2008 : 8:38:40 PM
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| I repeat from another post. If these multitude of disclosures are all for the benefit of the borrower, why aren't the lender's gross fee's and profits, including anticipated servicing fees, also disclosed to the borrower. I mean, the more disclosures the better....right? |
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hherrm
1407 Posts |
Posted - 03/31/2008 : 8:38:49 PM
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quote:
Originally posted by barrington79
So what's the big deal? This is what we're supposed to be doing.
DING...DING....This is what we are doing..duh? You could have used that moment it took you to post that s*** and did something constructive with your life.
The question is the new law..hence..the example I gave above. It says that you cannot change your fee's from the original disclosure. Have you even heard about that law? Or are you above it all? |
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barrington79
176 Posts |
Posted - 03/31/2008 : 8:53:09 PM
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quote:
Originally posted by hherrm
quote:
Originally posted by barrington79
So what's the big deal? This is what we're supposed to be doing.
DING...DING....This is what we are doing..duh? You could have used that moment it took you to post that s*** and did something constructive with your life.
The question is the new law..hence..the example I gave above. It says that you cannot change your fee's from the original disclosure. Have you even heard about that law? Or are you above it all?
"Ding..Ding" - I wasn't answering your question directly Jerk but simply stating my opinion that I feel such a disclosure is no big deal and how we should all be conducting business anyways.
As to your scenario, I imagine if you're submitting it to a different lender, then all you would need to do is re-disclose a new gfe and broker fee agreement since the old docs technically don't exist. Just make sure everything is dated within three days of the initial app. |
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hherrm
1407 Posts |
Posted - 03/31/2008 : 9:11:44 PM
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"Ding..Ding" - I wasn't answering your question directly Jerk but simply stating my opinion that I feel such a disclosure is no big deal and how we should all be conducting business anyways.
You are not the only one that thinks that we should conduct business that way anyway. Everybody here does, so I think it was a waste of your time to point this out.
As to your scenario, I imagine if you're submitting it to a different lender, then all you would need to do is re-disclose a new gfe and broker fee agreement since the old docs technically don't exist. Just make sure everything is dated within three days of the initial app.
Yeah, I can just see the new HUD booklet coming out stating that whatever fees have been disclosed can not be changed.
So in my case above, the buyer will come back and say: hey you told me that you only make this much on my loan, how come now you are making so much more. Duh, mister client, I found you a better rate, right? Client: but, if you are making so much more now, why can't you pay some of my closing cost, like it says in my HUD booklet. |
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