I've talked with some MBs and this is going to be a BIG DEAL. Their industry is mobilizing in this area and I would not be suprised the the proposal gets watered down significantly. Personally, I think a lot of the changes are long overdue and I don not see a major impact on appraisers. If it passes, I just see the industry upping their standard point schedule to cover the RESPA and GMPs they mis-quote.
I received a flyer with many bullet points but this one gets no tears:
"The new rule would make it ILLEGAL for a Mortgage Broker to receive more compensation than specifically disclosed on the 'Original Good Faith Estimate'".
Wow, and all this time I've stuck to my quoted fee on the appraisal - guess I should be hitting the MB up for a kick-back (Appraisal Spread Premium?) right before lock expires!
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>
American Guild of Appraisers OPEIU AFL-CIO [email protected]