Request for Information Regarding Promoting Access to Mortgage Credit

[Francois K. Gregoire]

Some here are very interested in the disclosure of "appraisal fee" splits between Appraisal Management Companies and Appraisers. Here's an opportunity to inform the CFPB and possibly affect their rule making.
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The CFPB is seeking public comment on a number of items related to Executive Order 14393—Promoting Access to Mortgage Credit. Some of these are appraisal related and may be of interest.

Request for Information Regarding Promoting Access to Mortgage Credit
Excerpt:

Zero Tolerance

Estimates of charges paid to creditors or mortgage brokers (or their affiliates) and transfer taxes are in good faith if the consumer is not charged more than the estimates. Estimates of third-party charges are also subject to zero tolerance if the creditor requires the consumer to use creditor-selected service providers (rather than permitting the consumer to shop for third-party service providers).

In response to the November 2019 RFI, several commenters stated that transfer taxes and third-party appraisal fees are particularly difficult for creditors to estimate within three business days of application and that the CFPB should not include these fees in the zero tolerance category.

 

[Zoe]

Some here are very interested in the disclosure of "appraisal fee" splits between Appraisal Management Companies and Appraisers. Here's an opportunity to inform the CFPB and possibly affect their rule making.
----
The CFPB is seeking public comment on a number of items related to Executive Order 14393—Promoting Access to Mortgage Credit. Some of these are appraisal related and may be of interest.

Request for Information Regarding Promoting Access to Mortgage Credit
Excerpt:

Zero Tolerance

Estimates of charges paid to creditors or mortgage brokers (or their affiliates) and transfer taxes are in good faith if the consumer is not charged more than the estimates. Estimates of third-party charges are also subject to zero tolerance if the creditor requires the consumer to use creditor-selected service providers (rather than permitting the consumer to shop for third-party service providers).

In response to the November 2019 RFI, several commenters stated that transfer taxes and third-party appraisal fees are particularly difficult for creditors to estimate within three business days of application and that the CFPB should not include these fees in the zero tolerance category.

I have emailed them and the White House and my senator.

I'll try again. They did email me back. My senator didn't. She won't get my vote in August.

She will probably win governor. I know secretary of state. She will probably be his new boss. I won't vote for her.

The secretary of state in TN has served under both democrat and republican and done well. He is republican.

 

[Zoe]

I really thought CFPB or FTC would jump in with both feet.

That is where me and my girlfriend Joan had so many problems on commingling of fees. Beautiful woman but wrong perspective.

 

[Zoe]

For the sake of being gracious, I won't ask you if TAF is familiar with Joan Trice.

 

[Bob Ipock]

I have said this 100 times at least. The BORROWER does not care. They know up front what the appraisal fee will be. They agree to it. They do not give a crap about appraisers or AMCs. They want to buy a house. Anyone who believes that borrowers will stand up and come to the rescue of appraisers.

When you buy nearly any product the price will be split many ways. You buy furniture, the manufacturer gets part, the store gets some, the trucking company gets some, the lumber company gets some. When someone buys a car do they want to know how the price is split up. Salesman, dealer, shop personnel, delivery, prep crew, rent, overhead. Who cares? I want the car. When I buy a house and I have bought dozens, I could not care less how much the appraiser gets, the home inspector, the painters, the carpet layers.....I do not care. I have agreed on a price and paid it.

This idea that anyone other than appraisers care about how any of the fees are split simply is ignoring reality. Do get the AMCs get too much....any do. This argument has been going on for 30 years and nothing has changed.