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Jan 15, 2002
Professional Status
Certified Residential Appraiser
New Jersey
Went to the HUD site and scanned the proposed changes to RESPA statements designed to "protect" the consumer from unfair mark-up of closing costs.

While I admit I currently did not read each and every word, the new changes seem to be tailor-made for companies like LSI, ValueIT, and others.

My reading of the regulations seems to indicate that a bank or mortgage company must disclose how much they pay for closing services such as a credit report or appraisal and any mark up. However, if the services are "bundled", they must disclose THAT amount, not each and every specific service.

HUD is convinced that disclosure will create competition and therefore lower costs to the consumer.

I believe the truth is that there will be downward pressure on the "parts" such as title search, appraisal, etc. You all know the line: "We can guarantee you 1,000 orders per year for $40.00 per order".

Then, the "bundler" charges the lender a set amount which includes a $300.00 appraisal fee.

The consumer does not "win". The lender wins, as many of the large banks and mortgage companies already own all or part of a nationwide servicing firm.

How far back does the disclosure reach??? Will the consumer wind up paying $300.00 for a $30.00 AVM??

Please let me know if I am letting my imagination get the best of me.

Site is:


George W Dodd

Senior Member
Jul 9, 2002
Professional Status
Certified Residential Appraiser

Nope, you got it figured right.
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