Thursday, October 29, 2009

What's the deal with the New GFE and HUD 1

Did you know that no where on the new GFE is there a place for the PITI. In fact for you to show that you need to have another sheet of paper which will disclose it. Unfortunately, you can not call it a GFE addendum, however you may call it worksheet.
For the life of me, and for all of the complaints of other people including loan officers, the old GFE at least provided this.
The change as taking effect on Jan 1, 2010 is significant. There are several areas that put the loan officer at grave risk to assume things to be a certain way. There is both an area for a 0% and 10% tolerance for certain fees. Most notably they are dealing with the escrows as well as the transfer and recording taxes. It's ironic how the loan officer who in his attempt to provide all of the information to the borrower must be aware of all of the fees which he has little or no control of. In addition, this also affects the Title Company who has to get the numbers correctly or they can be held liable.
This is another attempt by the large financial institutions, the Wells Fargo's, the Bank of Americas' and others to regulate who actually may originate a loan. After all due to their size and lobbying capabilit their loan officers are exempted from being licensed whereas the independent lender who is more fleet of foot and usually can provide a higher degree of service needs to be licensed through the new National Mortgage Licensing System for starters. After this they must take licensing exams for whichever state that they wish to originate loans in.
The only thing a loan officer who originate loans for a big financial institution needs to be is registered. Who would you believe will be more knowledgeable and stay more compliant?
Who ever said or believed bigger was better for the consumer. In fact it definitely fosters less competition and I maintain their is more price fixing as well as less value being delivered to the general public.
I hope that things will change but I fear not and unfortunately I believe that within the next decade there will be significantly less choices of people who you will be able to do a loan with.

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