FORUM: our attornies are preparing a reply to this regulation. We are coming out 4 square against it.
The good faith estimate is a good profit estimate for the lender.
The loser in this estimate is the consumer and every small provider, including the appraiser.
A little know paragraph in the regulation deals with the excess should the lender or provider of the service have money left over. THEY GET TO KEEP IT. Just a sceam to get around RESPA. The public gets screwer, the apprasier gets screwed, inspector and title people. LENDERS MAKE OUT LIKE THE BANDITS THE ARE.
We are going to discuss this Reg at our Conference in Atlantic City on Oct 24th at Trump Marina. All are invited 7.5 hours Cont Ed. NY, NJ, PA, DE, MD and Washington DC>
William Sentner
President
American Guild of Appraisers OPEIU AFL-CIO
[email protected]