goon squad that was so awesome I had to cut and paste it on my fb, hope you dont mind

It's late but I'll post this anyway. Someplace in here is a moral for our situation. THE ANT AND THE GRASSHOPPER This one is a little different... Two Different Versions! Two Different Morals! OLD VERSION: The ant works hard in the withering heat all summer long, building his house and laying up supplies for the winter. The grasshopper thinks the ant is a fool and laughs and dances and plays the summer away. Come winter, the ant is warm and well fed. The grasshopper has no food or shelter, so he dies out in the cold. MORAL OF THE STORY: Be responsible for yourself! MODERN VERSION: The ant works hard in the withering heat all summer long, building his house and laying up supplies for the winter. The grasshopper thinks the ant is a fool and laughs and dances and plays the summer away. Come winter, the shivering grasshopper calls a press conference and demands to know why the ant should be allowed to be warm and well fed while others are cold and starving. CBS, NBC , PBS, CNN, and ABC show up to provide pictures of the shivering grasshopper next to a video of the ant in his comfortable home with a table filled with food. America is stunned by the sharp contrast. How can this be, that in a country of such wealth, this poor grasshopper is allowed to suffer so? Kermit the Frog appears on Oprah with the grasshopper, and everybody cries when they sing, 'It's Not Easy Being Green.' Jesse Jackson stages a demonstration in front of the ant 's house where the news stations film the group singing, 'We shall overcome.' Jesse then has the group kneel down to pray to God for the grasshopper's sake. Nancy Pelosi and John Kerry exclaim in an interview with Larry King that the ant has gotten rich off the back of the grasshopper, and both call for an immediate tax hike on the ant to make him pay his fair share. Finally, the EEOC drafts the Economic Equity & Anti-Grasshopper Act retroactive to the beginning of the summer. The ant is fined for failing to hire a proportionate number of green bugs and, having nothing left to pay his retroactive taxes, his home is confiscated by the government. The story ends as we see the grasshopper finishing up the last bits of the ant's food while the government house he is in, which just happens to be the ant's old house, crumbles around him because he doesn't maintain it. The ant has disappeared in the snow. The grasshopper is found dead in a drug related incident and the house, now abandoned, is taken over by a gang of spiders who terrorize the once peaceful neighborhood. MORAL OF THE STORY: Be careful how you vote in 2010 & 2012.

Cluesdad: It takes a few days for the responses to show up on the Federal Reserve site. I think they must check them before they post them

Appraiser in the North - Cool, a bit long. But it gets the point accross. I have come up with lots of statements over the past year. Your reviewer is most likely not even in the same state as you. The only review of my work (California) was done by a gal in Texas, lol.

I just put the following in my final comments regarding a report of mine that got reviewed and cut from $130,000 to $90,000. "it is clear that the reviewer made an effort to find the lowest selling properties in the subject area that he could without finding out any details about those properties. This is not a review by a reviewer that took any time to get the data needed to complete a report that was worth the time put into it and underminds the efforts of all appraisers." Does any one think I went too far?

As the leading national association formed to protect appraisers’ rights, the American Guild of Appraisers (AGA) of the Office and Professional Employees International Union of the AFL-CIO has issued the following statement regarding HUD Mortgagee letter 2009-28: "We are pleased that the Federal Housing Administration has taken a position to ensure that real estate appraisers performing FHA assignments will be paid reasonable and customary fees and that fee requirements for third party organizations have been further clarified. The AGA believes that transparency of all fees benefits the consumer and enhances public trust. The AGA agrees that geographic competency is essential in providing quality appraisal results, and will continue to support ethical valuations that are vital to the appraisal industry. We thank FHA for addressing these important issues." For additional information regarding the American Guild of Appraisers visit: www.appraisersguild.org.

SoCal I am watching the little boutique brokers closing down and the bigger houses taking the cream of the crop with them. In the height of all the bad they are doing better because of it.. the writing is on the wall though. When the dust settles and theres 50 big brokers left the banks will crush them or buy them out..Eliminating the competition will only make the big guys fall harder

YOU ARE RIGHT ON THE MONEY LO in SoCal

I can't even imagine how much money B of A and Wells will make if they can turn us all into $20 hour employees. All the fees will stay the same, and the rates will go up since the competition is gone. That's been their goal for a decades now, this is their chance and they are going for it all out. If they get to keep all the YSP it is better than any other profit center they could dream up. The consumer has no idea how bad this is for them, the U.S. and anyone in the R/E industry earning a living. Banks would no longer have competition on rates. We know who is behind this idea.....The banks.

ok, if you saw my note from early this morning I just got back from my Drive-By for RELS (Wells Fargo). Got luck, the house next to it was for sale so I picked up the flyer and the subject home owner was there. So I asked about the area and she was sure I was looking to buy the house next to her. I have limited data on her house but that is ok, it is a drive by. Oh, for those that did not read the morning note, I talked RELS into $375 for a Drive-By, lol

In my opinion this new proposal would be unconstitutional. The ACLU needs to get involved if it passes.

Get this - “An accurate appraisal is an important part of any real estate transaction, and reforming the appraisal process is critical to the nation’s housing recovery,” said NAR President Charles McMillan. “Quality appraisals are threatened by unintended HVCC consequences and an inconsistency among the various federal regulators. As the leading advocate for housing issues, NAR calls on the federal government to establish consistent appraisal rules for FHA and the GSEs.” Note - He's calling on the FEDERAL GOVERNMENT to fix the problem. Supposedly, the most knowledgable people in NAR, NAHB and MBA can't figure it out so the bozos on capital hill are expected to!!!!!???? It's no wonder this country is going down the crapper. "Let Mikey try it - he hates everything!" Is it just me or has the whole country gone stupid? Oh yea - and now the Fed wants banks to loan money back to FDIC to fund saving weaker banks? Ever hear of the two farmers who were making a good living out of trading their mule back and forth until one sold it someone else? Who are they trying to kid - reeally?

Get this - “An accurate appraisal is an important part of any real estate transaction, and reforming the appraisal process is critical to the nation’s housing recovery,” said NAR President Charles McMillan. “Quality appraisals are threatened by unintended HVCC consequences and an inconsistency among the various federal regulators. As the leading advocate for housing issues, NAR calls on the federal government to establish consistent appraisal rules for FHA and the GSEs.” Note - He's calling on the FEDERAL GOVERNMENT to fix the problem. Supposedly, the most knowledgable people in NAR, NAHB and MBA can't figure it out so the bozos on capital hill are expected to!!!!!???? It's no wonder this country is going down the crapper. "Let Mikey try it - he hates everything!" Is it just me or has the whole country gone stupid? Oh yea - and now the Fed wants banks to loan money back to FDIC to fund saving weaker banks? Ever hear of the two farmers who were making a good living out of trading their mule back and forth until one sold it someone else? Who are they trying to kid - reeally?

I am all in for a march on Washington... can we make it on a day the Washington Capitals play so we can all see Alex Ovechkin?

Hey, I'm an appraiser but I hit the link and said my piece. I tried to sound like a consumer.... Here it is: The Federal Reserve has no business creating rules that will govern how Mortgage Brokers are paid. The reason Mortgage Brokers exist is because they provide a needed service to consumers. They almost always provide better rates and better programs than banks do. There are more regulations on brokers than there are on banks! Banks want you to get rid of their competition and you'll be doing what they want done. You are proposing to take away the yield spread. You are not proposing to take away the bank's. They get a yield spread also, they just call it by a different name. It is not the Federal Reserves business to enact laws that favor the banks over other institutions.

I think ALL loan officers and Realor's should go march at captial hill... But we would need EVERYONE in all states to do this... I'm in - any others??

Appraiser Mortgage Broker R.E. Agent: Bank Originators cannot speak with their banks owned appraisal folks either. DECENT, POSITVE ARTICLE in Origintion News called "Pushing Forward" - adapt and survive. JOECOLORADO - who opened a healthcare can of worms? Google: Britain healthcare NICE. Read some articles. Back to making money...........

Anybody see their own posts on the Fed website? I can't see mine that I posted this morning.

TxLnGirl....Thank you, you are so right! I'm caling the Wells Rep now. They are breaking the new laws already.

Oh Yeah a friend in the auto repair industry. Well insurance companies are starting to control that industry too. They're buying up repair companies and starting to make small independant repair shops like his get approved, which is agreeing to the insurance company's fee's for his work or they will never pay him for anything that goes through that insurance company, on any claim. WTF !!!!

Just reading all the chatter. Does anybody remember, it was recently, that the Banking industry was asking for approval on buying up real estate companies, and it was looking like they were going to get their way until the banks started crashing? I believe Street links an AMC was once nova star. I use to send loans to them. Now, they’re the same banking folks that now control appraisers. Well's Fargo has their own AMC that does their own appraisals...wow talk about double dipping. Jack off Cuamo doesn't have a problem with that now, does he? The AMC's are starting to go after the real estate agents business now too. So lets sum this up. Banks don't disclose anything - really, They crushed the mortgage brokering industry, they own the AMC's that controls/owns the appraiser through the threat of no more work and take almost half of his money, they would have owned the R.E. Corporate business world. Can you imagine the melt down in this country if they get their way? And all of this is ok with butt boy commie-pig corporate-scumbag-sell out Andrew Cuamo and almost all the current politicians. Welcome to your future. Wal-Mart, Microsoft, Bank of America, the WTO. The internet is a wonderful thing. Can anyone say slaaaaave?

to firstchl. Look for the paragraph on closed end mortgages, R 1366. Under closing dats for comments, click on the link :submit comment on this proposal." We need to get everyone on this discussion board to comment!

Once on the link scroll down just a little til you see "Rule Making Proposals". It is then the 3rd topic down - Regulation Z - Truth in Lending - Closed-end Mortgages [R-1366]. Hope this helps.

Why stop w/ us ?? Lets get rid of life ins salesman, health ins. salesman , investment brokers , stock brokers , realtors, title reps , drug reps , car salesman, all multi level marketing companies should go away...... Think about it, anyone paid a comission should be taken over and run by the government. Now add up how many people would be out of work as a result of this..... Now where do your tax dollars come from??????

Why stop w/ us ?? Lets get rid of life ins salesman, health ins. salesman , investment brokers , stock brokers , realtors, title reps , drug reps , car salesman, all multi level marketing companies should go away...... Think about it, anyone paid a comission should be taken over and run by the government. Now add up how many people would be out of work as a result of this..... Now where do your tax dollars come from??????

Why stop w/ us ?? Lets get rid of life ins salesman, health ins. salesman , investment brokers , stock brokers , realtors, title reps , drug reps , car salesman, all multi level marketing companies should go away...... Think about it, anyone paid a comission should be taken over and run by the government. Now add up how many people would be out of work as a result of this..... Now where do your tax dollars come from??????

I went to the Fed site to comment on R 1366 but could not find where to comment . Could someone tell me how to navigate it and where to comment ? firstchl@yahoo.com R 1366 is just another example of the Federal Reserve and the Government - both Republican and Democrat - to find ways toj kill the Middle class in favor of teh Bigg's . The Gov. and the Fed is not actually concerned with protecting the consumers . That is their spoon full of sugar to make the economy killing legislation pass .

I posted my comments to the Federal Reserve Board

""SIMPLETON: (September 22, 2009 8:12am) This is quasi socialism. Congrats America, this is what was voted for"" This is dead on correct! You guys need to forget about HVCC / MDIA and all the other garbage that has already happened. Worry about this YSP thing, becasue if this happens the way imposed, we are toast.

The following is a paragraph from R-1336 where it begins to talk about how damaging YSP is. I have a couple of questions after you read this. "For purposes of the FTC Act, an act or practice is considered unfair when it causes or is likely to cause substantial injury to consumers that is not reasonably avoidable by consumers themselves and not outweighed by countervailing benefits to consumers or to competition. As explained below, the practice of basing a loan originator’s compensation on the credit transaction’s terms or conditions appears to meet these standards and constitute an unfair practice. Furthermore, based on its experience with consumer testing, particularly in connection with the HOEPA proposal, the Board believes that disclosure alone would be insufficient for most consumers to avoid the harm caused by this practice. Thus, the Board is proposing a rule that would remedy the practice through substantive regulations that prohibit particular practices." First question, how in the world is a .5pt YSP causing "substantial injury" to the consumer? Notwithstanding all the points about loss of competition and such, this is such inflammatory language. If you want to talk about "substantial injury" to consumers, and if I could loosely compare YSP to retail markups, the consumer is getting KILLED (literally) in every other facet of daily expenditures with 30, 40, 60% markups on things we eat and drink. Where's the outrage? Second and finally, the whole tone of that paragraph makes me feel like we are being compared to CEO's of the "bailed out ones" and the outrageous bonuses they are STILL taking. Come on, they are pocketing OUR money and laughing in our face. We are simply trying to provide a professional service (and a great service if we do our jobs properly), earn a reasonable living, and be productive citizens-NOT CAUSE SUBSTANTIAL INJURY!

Thanks for the "Heads Up" I just left the following comment on the FED Site: Eliminating Yield Spread Premiums is ultimately harmful to consumers. Here's why.... All loans have some form of YSP. If I walk into my local S & L and take out a home loan, when the S & L sells that loan on the secondary market, they sell it at a premium, based on the rate. That, by definition is a Yield Spread Premium. But, since it happens after closing it's not disclosed (it's hidden from the consumer), and would not be prohibited under the proposed rule. As a broker, all compensation we earn, regardless of the source, must be fully disclosed and agreed to up front. This promotes competition in the marketplace which ultimately benefits consumers. Since a significant portion of a brokers compensation is paid by the lender, eliminating that income stream will force the broker to charge more up front, which put's them at a significant competitive disadvantage, and again ultimately harms consumers. Since more than half of all mortgage loans are originated by mortgage brokers, the big banks (who don't have to disclose their Yap's) would love to use this rule to eliminate their competition, again harming consumers in the process. Many borrowers now choose to have the lender pay all or part of their up front costs in exchange for a slightly higher rate. Indeed, in the current appraisal environment, sometimes this is the only way to make the loan work as their just isn't room to include the closing costs in the loan amount. Eliminating YSP will take away this option, which again harms consumers. Lastly, should this rule pass, the only way for a broker to stay in business will be to raise their up front fees (which will likely put them out of business) or fund their own loans via a warehouse line and then sell them to the lender (like the banks do) so the YSP would not need to be disclosed and would not fall under the prohibition. This again would be harmful to consumers because it would circumvent the current full disclosure requirement and allow the broker to hide from the consumer how much they're really making.

Thanks for bring R1366 to our attention. I did post my comments on the Feds website as did the rest of my office. They way they have it set up is a bit misleading. If you just read the header of what the mandate is about you would have no idea that it affects YSP so I think it is super you guys are getting the word out.

SoCalAppraisalGal; SANTA ANA, Calif., Sep 17, 2009 (BUSINESS WIRE) -- Veros Real Estate Solutions, an industry leader in enterprise risk management and collateral valuation services, announced it has been selected by Fannie Mae (FNM) as the technology provider for Fannie Mae's Collateral Data Delivery (CDD) system. Beginning March 1, 2010, Fannie Mae will require its lenders to submit full appraisal reports in electronic data format prior to loan delivery. In collaboration with Fannie Mae, Veros will be responsible for building, maintaining and supporting the CDD system, as well as handling direct lender integrations with the CDD system. "Veros is honored to serve as the technology provider in this significant project to increase appraisal quality across the mortgage industry," states Darius Bozorgi, president and CEO of Veros. "Fannie Mae is taking the leadership position in efforts that are long past due for capturing and analyzing collateral data." The implementation of CDD will enable a data-centric approach to better understanding collateral risk. In support of Fannie Mae's requirements for appraisal data submission, Veros is collaborating with Fannie Mae to provide lenders with flexible alternatives to connect to CDD via a direct system-to-system XML integration or via a web-based portal through which appraisals can be submitted either individually or in bulk. For additional information on Veros, valuation risk management systems, or the company's diverse analytic product portfolio, visit or call (714) 415-6300. For additional information on Fannie Mae's CDD system and related FAQs, visit . About Veros Real Estate Solutions Veros Real Estate Solutions, a proven leader in enterprise risk management and collateral valuation services, uniquely combines the power of predictive technology, data analytics and industry expertise to deliver advanced automated decisioning solutions. Veros products and services, integrated into industry leading companies, are now optimizing millions of profitable decisions throughout the mortgage industry from loan origination through servicing and securitization. Veros provides solutions to control risk and increase profits including automated valuations, fraud and risk detection, portfolio analysis, forecasting, and next-generation collateral risk management platforms. Veros is headquartered in Santa Ana, Calif. For more information visit or call Veros at (714) 415-6300.

BigAL, you're exactly right. Good luck w/ your new product/new job. I too will keep my license up with the hope that things will return to normal.(maybe when HVCC ends on Dec. 1st 2010?) After 80 years of appraising, you'd think the gov't wouldn't want to screw with what has worked for so long...

to "Lender" who posted at 8:48 this morning - Wells Fargo can not legally ask the buyer for $500 fee to get the approval process started - the new TILA on 7-30-09 stopped all that from happening, at least until 3-4 days after RegZ has been delivered to them. I would call them on it and let your buyer know that this is illegal!

JoeColorado - American law won't allow refusal of emergency medical care - so nobody's going to die here either... Major long-term illness may be another story. However, I hear the prospect of receiving timely care for gravely ill patients in Great Britian is not very good either under their system...

I just sent this link, plus the Fed link, to everyone in my database, along with a personal plea to review the proposal and comment according to their opinion.

Socal Gal- I'm copying & pasting text from the notice I rcv'd 09/10/2009 from EM/Encompass, clearly states $299/year & nominal fee after the first 30 assgnmnts. Client/Mrtg Co sent notice yesterday they're returning to using EM again and all apprsrs will have to get on board. Apparently they were flooded w/calls & msgs RE: the new charge to apprsrs which they knew nothing about. All apprsr on their list are nowing waiting to see what they find out from EM. I'll forward you the EM msg if you provide an addy. Copy & Paste follows -----> "Starting this fall, the Encompass Appraisal Center will be changing to a subscription-only service, meaning that only appraisers subscribed to the Appraisal Center will be able to accept orders through the service. Putting your ad and contact information in the Appraisal Center takes just a few minutes and costs as low as $299 per year. Your first 30 orders will be free; after that, you'll pay a nominal fee per order."<--- THAT's $299 PER YEAR for the first 30 asgnmnts ... wonder what the "NOMINAL" fee will be, 40%-50% of apprsl fee???

Actually, the National Health System in Scotland IS free for those that cannot afford it, and is available for all persons, foreigners(uninsured or otherwise) who become ill and are traveling through Scotland and need emergency care are included. The cost IS picked up and distributed throughout the working populace by the Internal Revenue Service via the P.A.Y.E system. The health system for prisoners, includes eye and dental care(which is not included in the National Health System) is also distributed to the general populace via the Taxation system. So technically it is not free, but it is free if you are poor or unable to pay. The reasoning is that no one should suffer or die because he or she is poor and cannot afford medical treatment.

If an appraiser stands up to a lender, then the lender either throws the appraiser under the bus or loses a Realtor who is mad at the appraiser. Cool world! HEY - I missed this new Fannie guideline: 401k and IRAs are now underwritten at 60% of actual value. Ok, but THIS was shocking: standard stock funds with post tax dollars are now only underwritten at 70% of actual value. Dangnabbit! Your lender may not be enforcing it yet, but it's coming.

I used the link and commented. We need more people to comment! Also, here is a link to the House Financial Services Committee. http://financialservices.house.gov/contact.html I just asked them when they were going to get off their duffs and approve HR 3044. It's great to let off steam in these forums BUT don't forget to write, call, email and fax those people who are "in charge." Your vocie DOES make a difference!

Appraiser Mortgage Broker RE Agent.Great response to that request.37 years in this business,I can't understand why appraisers don't take a stand against ridiculous requests and fees.Semi-retired and working part-time,I now prefer non-lender work.Be professional,work professional,produce a professional appraisal and demand what your worth.Keep up the good fight.

Rosalie - based on the front page story in the WSJ, just assume that bank based LOs are swiching to salaries with bonus instead of straight commission. The Fed will determine that straight commission adds too much risk to the mortgage pool as it improperly incents us.

It's all about the Law of Unintended Consequences. When a bunch of 'lawyer turned politician' types - in need of soundbites - try to regulate an industry, bad things will happen. Just look at the rules for TX(a)6 and how they hurt low income types. We need mortgage bankers in Congress. HEY TOM IN WISCONSIN - "did Congressmen pay closing costs?" Ask Chris "Angelo Gave Me a Deal?" Dodd!! Gotta go now - have to refer a client to ACORN for First Time Homebuying Training for Entertainers class.

Angry Appraiser, I am in the same boat you are. 16 years Appraising and being kicked out of the business. I know how hard it is to get licensed. Jump thru Hoops of fire to get to where your at, then the rug gets pulled out from under you. The greedy get greedier. I've been busy with FHA's, and after 11 years on the HUD Roster. Here comes the boot. Cannot trust the government to do the right thing. Never had. I am looking for another job and working on a new product. I can't wait to get out. And that sucks, because I really loved what I was doing. Stress is high around the house without income. I was waiting from OREA to receive letter to take upgrade test. One month went by and I got a letter wanting 2 more samples off my log. I already sent in 6 samples. I took the 50 hours education now I have to wait 2-3 months to take the test. They only gave us 10 months notice. I don't like the AMCs', had one job since May 1st. Now they ask me to reduce my fee to $225. NO WAY! I am out. I have my license for 4 years. So maybe in a couple years they'll give us back our right to get our own business. Appraiser's don't live in a free market society anymore. Our destiny is in other peoples hands and that is scary. This is a good way of releasing some of the frustration. Good Luck!

I wrote about this about 3 weeks ago. This proposal states actually will limit the broker to either earning a flat fee or an hourly fee. The broker will not be able to earn any money based upon the characteristics of the loan, ie interest rate (ysp), loan amount (origination fees), loan type, etc. While I believe that the broker has always proven themselves to be adaptable, this is going to prove to be a huge hurdle to overcome.

Great post clueless dad.. great one. think I'll adopt some of your comment into mine...

@Rosalie - this is for all ORIGINATORS. This isn't a banker/broker/retail LO thing - this is an ORIGINATOR thing. This won't hurt the banks - it will hurt us trench folks......

This is my post to the FED. "I agree that Loan originators should not steer clients into inferior, higher commissioned loan programs. Compensation limits appear to be a good direction, however it will limit the options for the consumer for many of the loan programs in place today. This provision as it now reads, will reduce competition, provide major market changes in the secondary Mortgage market, create much higher rates, provide a huge angst with the financing arms with the secondary market and provide a real threat to maintaining some sort of stability in this fragile housing market. The intent of this provision should be focused on any future loan programs that can/will be developed by an institution, private or otherwise, that will be sold to another counterparty within a given time period. Steering occurred primarily with the advent of subprime and option arm loan programs. GSE, FHA, and VA loan programs, because of their sheer number and consumer awareness are able to be shopped competitively by the consumer. It is very difficult to charge a higher rate on a loan nowadays, as the public has become VERY aware of the going rates and terms on their residential financing. This market competition will provide the free market solution to the steering issue. The GSE, FHA, and VA programs should be exempted from this YSP issue. Future non-portfolio loan programs need to abolish YSP altogether, or have their YSP premiums much lower than their GSE and FHA counterparts."

Lender, I hope you put your Wells Fargo scenatio in your comments on this reg. This is steering, and we've all seen this happen to us.

just STOPPED the video and went and commented on the proposal...did you?

FT - I don't know what you're talking about.. look to your right and click on the fed reserve logo..

I am SO frustrated with all of this government meddling. I feel like everyday I am in a fight to stay in business. WHEN is this going to stop? I write my legislators every week. I wish everyone would do the same! Thank you for pointing me in the direction for comments on R-1366. I only hope our voice is heard....

no links and docs box

On the Proposed Fed Rule: How is it that in every other industry, negotiation for price & terms (rate, YSP, fees)is an expected & inherent part of the buying/selling process- but when it comes to "buying" money, Barney & the Gang feel it's necessary to interfere in this tradition? This is the "dumbing down" of Americans, and no single person who lives on this soil should tolerate it- for themselves or their children, who are inheriting this mess.It is virtually the back-door means of red-line reintrodutcion by making home ownership unaffordable again. Stand up for your rights, and those of the next generation!

Steering occurred primarily with the advent of subprime and option arm loan programs. GSE, FHA, and VA loan programs, because of their sheer number and consumer awareness are able to be shopped competitively. They should be exempted from this YSP issue. Any non-portfolio private or bank future loan program should have this YSP provision.

Starving appraiser on Ellie mae/Encompass...funny you should have that question. I spoke for a long time on friday with the girl running this for Ellie Mae/Encompass. I was told it was a one time fee of $299.00 not just for 30 orders and there was no other fees....Ellie Mae/Encompass from my understanding is a software company. Its clients can utilize them as a way to order appraisals. The one they ordered with me last week was FHA so I told my client to just send it directly. Their employee told me they are doing this to gear up for some new regulation in March of 2010 that demands an electronic paper trail for each loan...not sure what thats all about but that is what she told me...I was told I could still charge my full fee..but again why go thru a middle man for an FHA deal? Anyone know anything about this new requirement on a paper electronic trail mandatory as of March 2010?

Used all 2000 letters and comments about same. Added that if should pass to eliminate brokers, then to be fair, lenders/banks should also only be allowed to make 1% gross income. (There audits would need to reflect this. Their additional audit cost would probably exceed the 1% gross)

Mad LO, you hit the nail on the head.

D: No Were they supposed to help the consumer? LOL

Can anyone identify any changes relative to regulations and laws in the past two years which have reduced cost for borrowers, made disclosures easier to understand, shortened processing/underwriting times, or improved the overall process?

My comment to the Federal Reserve Board: "Regarding the following verbiage "Prohibit payments to a mortgage broker or a loan officer that are based on the loan's interest rate or other terms". This may seem like a good idea at first, however this rule would drastically limit the consumer's mortgage financing options. Currently mortgage lenders can use their yield spread premium (also referred to as "YSP" or "Premium") to help pay the borrower's costs, and in general can reduce the borrower's upfront expense. In certain cases, the borrower may not have sufficient funds to pay all or some of the related closings costs related to obtaining mortgage financing. This premium allows the lender to assist the borrower in structuring the financing to meet the borrower's individual needs. Without this pricing flexibility, the borrower's options will be reduced and the lender will be forced to charge all related costs to the borrower directly. This will inevitably restrict some peoples ability to purchase a home. This rule, however well intended, is not necessary for promoting consumer protection and will have an adverse impact on the same consumer it seeks to protect. Please consider removing this clause from the proposed rule. Thank you."

If that goes thru, we will all be working for B of A and Wells for $36K a year. This is what they want folks.

Here are my comments to the Fed. Section in question is Closed End Mortgages. Eliminating yield spread premiums will also eliminate no-cost mortgages. For borrowers who have little or no equity, the lenders ability to pay their closing costs out of YSP's allows many to refinance that otherwise would not be able to. Also, potential homebuyers would lose the ability to purchase a home if they don't have sufficient funds to pay all their closing costs. The demise of down payment assistance programs has limited the number of families who can afford to buy a home. All their cash has to go to the down payment. If lenders cannot pay some or all of their closing costs from YSP's, then they are effectively eliminated from the home buying market. Is this what you intended? I think not. Saying that all lenders "steer" borrowers to high priced mortgages in order to earn higher YSP is untrue and misrepresents those of us who often use YSP to assist the home owner/buyer when they don't have sufficient funds to complete a transaction. Not all mortgage lenders and brokers are unscrupulous. Please do not throw out the baby with the bath water in making blanket rules to purportedly protect the consumer. You've already screwed up enough with MDIA that has created major problems for the consumer, most of whom are unaware of these changes and the cost associated with them. Longer lock periods are now necessary to meet these requirements, resulting in higher priced loans to the consumer. This is not what you intended either, but that is the result. Your failure to research the result of these rule changes has had a deleterious impact on the borrowing community - not the opposite. RESPA disclosures were already required well in advance of any closing AND YSP's have been disclosed for some long time now - except, of course, by banks - who appear to be exempt from disclosing anything that might relate to profit. And calling a YSP by any other name is utter nonsense. Many banks state that YSP’s are Service Release Premiums! Who are they kidding? Certainly not me. By creating this longer waiting period through MDIA, borrowers can no longer take advantage of low rates because they have to lock for 45 to 60 days - and we all know that longer lock periods cost more! Do your homework. Also, the amount of YSP (and including total other fees) that any lender can earn on a loan is already limited to 3% - 5% in most states. Why are you trying to tell us that we can’t make a living? Who tells you how much money you can earn? If I had your government salaries, I wouldn’t need to work at all. At age 66, having been a mortgage broker for 30 years, I would love to retire. However, all the YSP’s I’ve ever collected won’t allow that and I am still plugging away trying to help people buy a home or refinance into a better loan. The elimination of YSP’s will further limit the ability of mortgage brokers to earn a living, thus further reducing the consumer’s choices. Is it your intention to allow only banks to make mortgage loans? If so, 80% of those seeking to purchase a home or refinance, will end up on the scrap heap. Once declined, banks are unwilling to work as hard as a mortgage broker to get the loan done. I have worked with borrowers for months and months trying to get them ready to buy a home. Haven’t I earned my fee? None of my borrowers have ever complained and none ever will, since I don’t gouge them with higher rates simply to line my own pocket. Please take into consideration all of the above factors before passing these changes.

Bank trying to take over the industry will provide less competition, which drives up rates. If his goes thru folks can expect more of what happened to me yesterday. One of my buyers had to get a prequalification letter thru Wells Fargo to get his offer in, upon talking with Wells and faxing them his financials, they said it would cost him $500 upfront to get the prequalification letter he needed to get his offer in, which they said they would credit back to him at closing if he used them. If he didn't win the offer for this house he needed the prequal letter for from Wells, he needed to use Wells for financing for any other homes to get his $500 back. This is my buyer and I'm doing the loan, but they try to steal them this way. My buyer backed out of the offer. These banks are greedy.

ANDY, You hit the nail on the head. The lenders/banks caused the problems by not doing the reviews if a appraisal was over valued. If there underwriters did there job we would not be in this mess. I have been a LICENSED APPRAISER for over 18 years and have had so many problems with UNDERWRITERS who do not have the experience or the knowledge or LICENSE to read or understand a professional appraisal report. I have had them ask for the dumbest things including a additional comparable on a report with 6 comparables. Oh well. Now with 10-1-2009 coming I can no longer do FHA orders because I'm only LICENSED. Only CERTIFIED appraisers will be doing them because they can do orders over a million. What a fu----- joke when HUD/FHA limit is $729,750 in Calif. Folks another Goverment regulation that was pushed through by the lobbyest as WE APPRAISERS HAVE NO VOICE.

I am sorry about the long post. The simple solution to this YSP issue is to exempt the GSE, FHA, VA, and maybe the RD programs. All new future loan programs outside these areas should, IMHO, have this provision.

Hi Joe, I'm not following your logic. Medical Costs are not FREE and Oil in Libya is a windfall of cash. I'm not sure I follow. Also I don't think remembering 9/11 is unique to you but that seems to be what you imply. I think Harber was spot on with his reaction to those jerks. I bet he hasnt forgotten 9/11 either.

Folks, it's more than just YSP..........here is from page 55, middle column.........------->"Under proposed § 226.36(d)(1), a loan originator would receive the same compensation from a particular creditor regardless of the transaction’s rate or terms."<--------------THE SAME REGARDLESS OF RATE OR TERMS.......can you say FLAT FEE PER LOAN?

They really haven't thought this whole issue through. Again, I agree on principle that a loan originator should not be able to steer an applicant to a higher based YSP, when the program itself is inferior to the consumer. With only a small number of loan programs available nowadays, the amount of competition in rates and fees is keeping the loan originators from steering clients to higher based YSP's. This problem of higher YSP's was as a direct result of non-federal agency loan programs that twisted consumer perceptions. As an example, remember the pricing on Pay Option Arms? Consumers didn't care about the margin, many didn't even know what it meant. The progam was a lower payment and that is all they cared about. Housing prices were rising and that extra negative was going to be much less than the appreciation in their house. The commission was based on Margin and the prepay penalty. You could earn 3-5 points on a high margin and a prepay penalty. Look at the subprime products that were issued. These products enabled the consumer to get a house. But the consumer they attracted was so excited about the prospect of getting "in on the action" they only cared about their payment and how much money did they need to close. Taxes and Insurance? "We will pay them later with our future bonuses." You can only disclose everything to everyone, but the bottom line is that it was their choice. This issue of steering occurred outside the mainline GSE, FHA,VA, or RD loans. ( Watch out for the RD loan pools. These loans are 100% financing, used outside of urban areas, uses very low FICO scores, and is based strictly on lower income qualification. LO's are steering their clients to this program like crazy. A future foreclosure problem? You tell me. DUH!) It is the new program in many areas, such as most of the state of Idaho, outside of Boise and Couer d'Alene. This "steering"problem was caused by all the loan programs securitized by Wall Street. The solution should only address these future loan programs and exempt the GSE, FHA, VA, and maybe the RD program. It is a simple solution to this issue. After all, how would the lenders compensate LO's on GSE and FHA products? Salaried? I doubt it. Fixed payments per loan? I can't see how they could do that. And how would the secondary market work? Think about that major hurdle. These guys haven't thought that process through at all. The unintended consequence of putting roadblocks on the secondary market for FNMA and GNMA's would crush the market, raise rates and "pi**off" the Chinese. And this govt cannot afford to have our new financing arm mad at us.

This is my post the the Federal Reserve for R-1366. You are taking the right away for the consumer to do a no cost loan by taking the ysp away. If you take ysp away, the consumer will not be able to pay for the refinance of their home. Many need to roll their loan out of an adjustable into a fixed low rate. Since homes are not appraising, the consumer will not able roll in the closing cost into the loan due to the loan to value. The option is to either pay for closing cost out of their pocket or roll the closing cost into the ysp. If you take away the ysp, the only option will be to pay for closing cost out of pocket. Who has enough savings to pay for closing cost? Who wants to use their saving (reserve for emergency) to go toward closing cost? These are difficult times! Guide lines are becoming stricter so less consumers are able to refinance as it is which will increase the number of foreclosures. Many people need to get out of adjustable rates and roll their loan to a fixed rate. Many people need to roll their loan to a lower rate...to lower their monthly payment. We already are not able to refinance the stated income consumer, now you will not be able to refinance the W2 income individual because they do not either have or want to put their emergency funds towards refinancing. We will see even more foreclosure if you take away the ability to pay for closing cost to refinance their loan. You are not protecting the consumer, you are hurting them more! Cut the consumers a break! Lets not see more foreclosures because they are not able to refinance. Also if you take away the ysp, than less people will be able to purchase homes. The purchase consumer is helping our economy! So your are just going to hurt our economy more if you take the right to roll closing cost into the loan.

Post on 1366: The mortgage and real estate industry is in a sad state right now. The main cause of this was "irrational exuberance" in the thought that home prices could only go up. EVERYONE made this mistake, from the real estate agents, the banks, the borrowers all the way up to the federal government. Prices had never declined, so why would they?? We all know better now and the industry has already cleaned itself out of the "bad loans" and also the bad mortgage companies. Right now the last thing the industry needs is more negative changes. The HVCC has proved to be disastrous for the average consumer, costing them time, money and in some cases keeping deals from closing at all, due simply to the fact that the appraiser did a poor job. As far as R-1366, the elimination of yield spread premium will only limit competition and also limit the options that a consumer has. As a broker, we can offer no closing cost loans, because we can pay all the fees for the borrower out of the fees that we earn from the bank for doing the loan. This has been a great way for people to take advantage of the low rates and not add back in costs to their loan balance. If you take yield spread away, you take away that option. It will also create less competition on the market place. Big banks to not disclose yield spread (even though they usually charge a higher rate) so they will not be affected by this. The one’s that will be affected the most is the small company that earns a living by giving the client the best deal. If the big banks gave the client the best deal, there would be no need for Broker’s and small lenders... But they don’t. If we eliminate how the small guy makes money (while still giving the client the best overall deal) we will destroy competition and ultimately cost the consumer more money. Please reconsider the elimination of yield spread premium.

Here is my post for the Federal Reserve: Please review the long term impacts of the passage of R-1366. Yield spread premium is NOT a tool to enable brokers to 'make more money by selling a higher interest rate loan', but a tool to enable the borrower to choose what structure of the mortgage financing is going to fit their needs best. If a consumer plans to own a home for a shorter period of time, it only makes sense for them to eliminate some of their up-front expenses (which can be paid by the originator out of the YSP instead of by the client). If YSP were to be eliminated, all clients would have to pay ALL of their expenses up front, thus forcing some consumers to pay MORE money for the financing of their home. An experienced and well trained loan officer will walk a borrower through multiple options and help the client choose what makes the most sense for their needs. Take this example of two consumers with very different needs. Two people need to buy new cars. Person ‘A’ drives 100 miles a day to and from work. Person ‘B’ takes public transportation most of the time, but needs a car for very occasional or emergency use. Person ‘A’ should obviously choose a gas electric hybrid car, even if the premium to purchase it were to be $5,000 more than a comparable gas-only vehicle. This is because over time, person ‘A’ will recoup the additional premium spent on the vehicle in the gas money they would save, and would likely save even MORE money over the long term; a good choice for person ‘A’. Person ‘B’ should reasonably avoid paying the extra $5,000 for a hybrid, as their gas consumption savings would likely be dwarfed by the added expense of such a vehicle. R-1366 is like forcing person ‘B’ to spend that extra money on a hybrid car despite the fact that it is not financially in their best interest. R-1366 will eliminate the consumers’ ability to choose the strategy that best fits their personal needs. Granted this analogy may have environmental implications, a consumer’s decision on mortgage financing structures does not. Government involvement in mortgage financing should seek to provide nationwide licensing and educational standards for loan originators as well as reasonable amounts of consumer protection, not for price or market manipulation. You have to be licensed to drive a car, but you don’t need to be licensed to originate a $400,000 mortgage???

So when Haber told Ghadaffi to pound sand, he was actually working in the best interests of his client?.....good for him. But when Scotland let Cancer boy go back to Libya on compassionate grounds, we dont seem to have taken into account that Scotland has an extremely good FREE Medical System, with FREE Cancer treatment options, with FREE medication and FREE doctors....Libya has .....sand....lots of FREE sand.....and oil......which is not so free.....how compassionate is that? Now Libya has to pick up his tab for their murdering "hero" BUT the victims of the flight will eventuallly really get their day when he meets his maker and they are the co-op acception committee.(actually the medical costs are not free, they are paid for by the working people of Scotland which are included in the Internal Revenue Taxation system). I havent forgotten the horror of that day(or 9/11) and I suspect I never will, but if we want to bring ourselves down to his level, then we have lost everything we have tried so hard to gain and maintain as Americans. Shame on you.

YOU ARE AN IDIOT Central Valley: (September 22, 2009 7:58am) Ok, I have to open my big mouth and I know I'm going to get hollered at but, lenders, quit complaining about low "values" that is what this entire HVCC is about. Address the technical quality of the report, the competence of the appraiser, and the selection/reliability of the data. None of this would be in violation of the HVCC. Discussing/influencing "value" is. remove the word "value" from your vocabulary. It will get you a lot farther!

wow, nobody was all that upset when the appraiser'sfee went from $375 to $175 because that was what the AMC was willing to pay for the same amount of work if not for more work (1004MC) and now that it afffects the rest of you now it's a big deal? Do what the appraisers do; find a new career, move out of your nice home and find a small apartment to live in, and file for bankruptcy.

Hammer is dead on folks. No vote is involved. This is NOT legislation via Congress, this is a Federal Reserve Board "regulation". The Public Comment period IS your only way to 'vote'. Comment with intelligence, not emotion. It will be available to read for years to come. Pasted below is the text to look for on the Fed's comment listing page (http://www.federalreserve.gov/generalinfo/foia/proposedregs.cfm, this is where the Fed logo button to the right will take you): Regulation Z - Truth in Lending - Closed-end Mortgages [R-1366] Proposed amendments that would revise Closed-end mortgage disclosures to highlight potentially risky features such as adjustable rates, prepayment penalties, and negative amortization and prevent mortgage loan originators from "steering" consumers to more expensive loans Closing date for comments: 12/24/2009 Submit comment on this proposal <----go here to Comment View comments on this proposal

Reqarding 1366: Having a mortgage broker, lender, or banker to not use YSP is a foolish idea. Why would you allow this? This will mean that the consumer will have fewer options, higher rates, and higher fees to obtain a loan. This means that no points and no closing cost options will be gone-once again bad for the consumer. This also means that a consumer shopping for the best rate won’t have the ability to negotiate with the loan officer for a lower rate-once again bad for the consumer. After all the legislation that has happened over the last 2 years you think this is a good idea? Loan officers have to be individually licensed which cleared out most, not all, of the bad apples in our industry. I know in Massachusetts there were 30,000 active loan originators in Massachusetts in 2007 and only 5700 signed up for their individual license. Don’t you think that has more of an effect on creating a good lending environment? Why stop YSP from the good ethical people that are left? Why don’t you ban commission for realtors? Why don’t you ban commission for financial planners? Why don’t you ban commission for car salesman? Why don’t you ban commission for everyone? Why you don’t do this is because it is stupid. By not allowing YSP you will put tens of thousands of small mortgage brokers out of business. Is that better for the consumer? Is that better for our economy? I think you know the answer.

ANDY: I've been told that if I'm not asking for value and just address the technical aspects then I won't get a value increase. On the HVCC issue I've got now the appraiser hasn't addressed minor details like brick vs. siding, minor construction features such as green building/insulation/energy efficiencies, features of the house like microwaves, and has pulled comps from inferior areas and not adjusted for that. I've gone thru 3 reconsideration processes and have gotten a form letter rejection because the AMC can't even get the appraiser to look at the data. I've talked to 2 other appraisers who have pulled comps for me and they've both told me the other appraiser artificailly limited his comp search to the sales price and under. Had he used more liberal search parameters he'd have found multiple comps at about $10,000 above sales price. That just proves you can sell a house at too low of a price. They buyer got a bargain and everyone but the appraiser knows that.

Frank!!! I got one for you!!!! I am about 90% Realtor Referral based and lately it is near impossible for my Realtor Partners to get their buyer into contract. Some of my Realtor partners got a sickening offers. In this case, the listing agent offered to give our buyer the contract if the buyer would give him $10k on the side. Can you believe that S#$^!!! The nerve!! This is what it has come down to. Listing agents get in bed with Asset Managers and then have total control of what offers are presented. This is beyond unethical and there is really nothing in place to counter it. I already contacted local TV and Newspaper hopefully I can get something going. People need to be aware of this stuff.

Page 51 thru 56 for sure.... On my previous post I state 5% cap that is borrower and lender paid fees. Origination and YSP as well as all other APR.

This is directly from page 55.........you couldn't place the loan with a different lender because they pay better - think Provident vs. BoA. "The Board believes, however, that there is benefit in attempting to craft a rule that prohibits and deters the most egregious practices, even if such a rule cannot ensure that consumers always obtain the lowest cost loan. Under the proposal, a loan originator would have a duty not to steer a consumer to higher cost loans that pay more to the originator when the loan is not in the consumer’s interest. Originators would violate the rule, for example, if they directed the consumer to a fixed-rate loan option from a creditor that maximizes the originator’s compensation without providing the consumer with an opportunity to choose from other available loans that have lower fixed interest rates with the equivalent amount in origination and discount points."

This is quasi socialism. Congrats America, this is what was voted for.

Guys, just realize this is MORE THAN ELIMINATING YSP - it's about controlling/fixing what the originator can make, whether banker, broker, retail, it doesn't matter. Forget about YSP, what if you were told you could only make a flat $500 a loan?!! Or less?!!!!!!!

Thanks for bringing our attention to R-1366. Here is my comment that I posted. Others need to do the same. If I am reading this correctly, this proposal is going to eliminate the availability of yield spread premiums to Lenders and Brokers. That could possibly cripple the consumer's ability to get a conventional mortgage. Let me give you some examples based on a purchase of $175,000 with 10% down payment and a loan amount of $157,500. Credit Score 680-699 an additional cost of $1,181.25 in closing cost Credit Score 660-679 an additional cost of $2,756,25 in closing cost Credit Score 640-659 an additional cost of $3,543.75 in closing cost Another example: a cash-out refinance based on an appraised value of $200,000 and a loan amount of $160,000 which is 80% loan to value Credit Score 680-699 an additional cost of $4,800 in closing cost Credit Score 660-679 an additional cost of $6,600 in closing cost Credit Score 640-659 an additional cost of $8,600 in closing cost All of the figures for the charges I am providing are due to the additional fees lenders are charging. Without the consumer being able to choose a slightly higher interest rate and use the YSP to cover some of these fees, they are going to have to pay for them out of pocket. Not only will this hurt the consumer's savings, but depending on the exact loan scenario, some will not even be able to do the loan because the upfront fees will exceed high cost loan limits set by the HB 552. I feel you need to examine very closely the disruptive impact this could cause on the housing market and the mortgage industry overall.

In Indiana we are capped at 5% total fees that can be borrower paid and are included in the APR. I recently had a $132K purchase and the borrower was only taking out a $25K loan. The realtor in addition to the 6% that they are charging the seller had the buyer (my borrower) sign 2 documents that the borrower would pay $275.00 in closing fees to the realtor and also $75.00 in an electronic storage facility so that the borrower could access their closing docs anytime within the next 7 years. Normally I would not make any waves about this but with the loan amount being $25K the extra $350.00 burden is an APR cost. There is no realization or benefit of this to the buyer/borrower. So I believe the controling agencies need to look at other items other than YSP/SRP!

Ok, I have to open my big mouth and I know I'm going to get hollered at but, lenders, quit complaining about low "values" that is what this entire HVCC is about. Address the technical quality of the report, the competence of the appraiser, and the selection/reliability of the data. None of this would be in violation of the HVCC. Discussing/influencing "value" is. remove the word "value" from your vocabulary. It will get you a lot farther!

I just threw up in my mouth... Are u kidding my what are these idiots doing... I have been in the mrotgage industy for 20 yrs and all the harm that has been done in the past few yrs is a direct result of wall st greed. now your going to punish the working man ??? what a Joke... Please get everyone you know to click on the link and comment so that your voice it heard.

Please scroll down and read "How to fight the regulators" post - it is on the money, he is one of the few people who realize that this is going to kill originators NOT the banks - and will likely wipe out third party origination as we know it.

Just was told this by one of the AMCs. He told me I shouldn't be asking for a reconsideration of value on a low appraisal. He said my wholesaler should be asking for the reconsideration. He said that if my wholesaler reviewed the appraisal and asked for the reconsideration and his appraiser refused to look at it then he could fire the appraiser. That wouldn't help any of us on the low appraisal but he wouldn't have to use him again. What prompted this conversation was he told me he'd ASK his appraiser if he'd revisit the appraisal to see if he could raise the value.

I use my yield spread for first time homebuyers almost everyday...I place my 1st time homebuyer and short term mortgage in a premium pricing situations...Say, there is $3500 in closing cost and some prepaids. My first time homebuyer is NOT going to make up that difference in principal reduction in three years. The sound choice is to have the slightly higher interest rate, use the YSP to cover cost, and my borrower comes out way ahead in the 3 years (1 year to) - Paying closing on anything but a mid to late term (5+ years) is doing nothing but putting your borrower in a worse financial position - they are not going to make up the closing costs and lower interest rate perceived benefit up against principal reduction. Do the math yourself...

http://www.huffingtonpost.com/ellen-brown/landmark-decision-promise_b_292333.html

Here is a link to the actual document for those that want to read it....it is R1366. Pay special attention to pages 52-56ish. http://edocket.access.gpo.gov/2009/pdf/E9-18119.pdf

I feel that there are many changes than needed to be made in the mortgage industry, a lot of them have already been changed and I am certain there are more to come. It is no surprise there needed to be changes, but it seems like some of the changes are made or proposed without any rational thought. For example HVCC was and still is one of the worst ideas ever made in the mortgage industry. It is costing the consumers more time, money and even costing them their home. Not to mention the number of jobs that are starting to be lost because of it mainly independent licensed appraisers. The next worst decision in the mortgage industry will be if you decide to eliminate or change how the banks pay a yield spread premium. This will only allow for consumers to have fewer options and end up paying more money for the same type of loan in the long run. Not to mention all of the countless jobs that will be lost. I completely agree with another gentleman’s comments about this. It will not just hurt the industry or cripple it, It will KILL it. You will essentially put hundreds of thousands of people out of jobs, and in this current economy, how are we supposed to find new jobs? I am all for the Government making more horrible choices if they are also proposing they we (the entire mortgage industry) will be included in the change and giving jobs with the Federal Government making at least what we did before if not more.

Also, the end of your video is freakin' hilarious and should be at the beginning, not the end...!!!!

The thing that scares me the most about R1366 is that it doesn't need a vote from ANYBODY. Just a stroke of the pen, and our lives change. It's not just elimination of YSP - it is the concept of changing our "scale based" form of quoting rates, allowing the free market (and sales skills) to dictate our income. This "let's be fair to all kumbaya" nonsense about a flat fee would mean that we are going to make tremendously less on each file. Our job then becomes a $35,000 a year desk job (think phone bank at Quicken loans), brokers AND bankers would disappear (my opinion)...........especially pay attention to the pages in the 50s, 52-56 I think. Be sure to post CONSTRUCTIVE comments people!

As long as the borrower knows they are paying for yield spread premium, then let's keep it. I am a direct lender but dont want to lose competition. It is good for everyone to compete. Many of my clients take higher rates because they are told by brokers they dont qualify for lower rates. This has to do with competion, not ysp.

Please people call your congressman and representatives. Your comments here are mostly good but do very little to help with the actual cause. Time to stand up and take action for yourself or action will be taken against you. Your choice!

Appraisers - 3 year inspection discloser goes into effect with the new USPAP Jan. 1, 2010

it looks likes this, it's just a few steps down .. at the bottom of the little paragraph it says, Submit comment... Regulation Z - Truth in Lending - Closed-end Mortgages [R-1366] Proposed amendments that would revise Closed-end mortgage disclosures to highlight potentially risky features such as adjustable rates, prepayment penalties, and negative amortization and prevent mortgage loan originators from "steering" consumers to more expensive loans Closing date for comments: 12/24/2009 Submit comment on this proposal View comments on this proposal

James - I think the 3 yr disclosure rule goes in to effect in the near future, but can't put my hands on the exact date....I'm looking. And do remember, even w/drive-bys apprsr must be able to produce a credible report. Those that have never been in MLS usually turn out to be a full URAR for me... not enough detail on county records and accurate/very close SF is a must. THANKS C-Valley.

R-1366, just croll down a little it's there.. Post and read comments

Perhaps if someone would provide specific easy to follow instruction to all the mortgage brokers that follow you on what link to submit comments to it would be easy enough to increase the number from 300 - 3000.. Make it simple for the simpletons...

This is another perfect example of when government makes decisions for people that they would not do themselves. How many of these people who proposed and support this bill paid points to buy THEIR home or paid points to refinance? I would bet not many....but if they did, it was a CHOICE to do so. Any decent loan officer gives their customer OPTIONS to either pay points, pay only third party closing costs, or no costs whatsoever depending on (hold your breath) what would be best for the CUSTOMER. Let the consumer choose! Where do these "experts" come from other than the pocket of some legalized bribe system (Lobbyists)?

Starving Appraiser - AMC! James the Appraiser - Drive-By, you better re-read stands. 1 & 2 USPAP. USPAP - Disclose prior inspections (3 years), from what I understand

They have his phone number, the company he works for, his pic and now they've heard him tell the world he thumbed his nose at Libya so don't be surprised if he turns up missing.

New USPAP Rule ? - All Appraisers, can you tell me whatthe new rule about appraising a home a second time in 3 years is about? I was told it would come up in my next USPAP class.

Small Victory - I got RELS (Wells Fargo) to give into an Appraisal Fee of $375 for a Drive-By. I told them the property was 9+ Acres and Rural. It had never been on the local MLS. Now all I have to do is use the public record info and $375 is mine, so many areas of the form will be N/A that I should get this done in under 2 hours as I eat lunch, who said no free lunch

QUESTION??? - Ellie Mae/Encompass will soon charge APPRAISERs $299/year for the first 30 orders rcv'd through their service/website, and a "nominal" fee for each assignment after the first 30/year. Does this make them an AMC? What is the definition of an AMC?

our links go to the same page. Read what it says and follow it.

Hey boys, there must be 50 links on the Fed Res Board site to comment on, WHICH one do we click?

Pitch forks und torches in da streets! Ve vill GET zis monster!

Appraiser Mortgage Broker R.E. Agent: - Could that AMC possibly be from Corapolis, PA? They try that cr__ with us all the time. I agree!

Why let banks keep more money so that borrowers will have to pay more??

Just got an appraisal order for a 6000SqFt house on the gulf of mexico - almost one acre - three stories high - probably around $3 million , corporate owned - as of last month, with a lis pend in o8. They want a full appraisal, with all their extra's, plus 1004mc, in 24 hours, for $190.00? Go Fu.... yourself

This threat is REAL. Yes R-1366 is a long document; however you need to read it, understand it, and comment on it. Below are a few things to keep in mind as you take action on this proposed rule. 1) Although the threat of loss of YSP is real, the rule does propose alterntvies that may be pallatable. 2) The limitation or elimination of YSP compensation affects the mortgage broker, third party originator, loan originator, AND RETAIL BANK loan originator. This rule affects the person (you and me) writing the loan applications. For example the big bank can make as much as they want, but will be limited in what they can pay their loan officer. Those of you thinking working for a bank will save you are dead wrong. 3) NAMB is the ONLY organization in Washington DC that represents the voice of the individual loan originator. Wheter you love'm or hate'm, they are your only shot in Washington DC to negotiate this proposal. They need membership and money to fight this issue. Go to www.namb.org to become a member. 4) When you comment, bashing and name calling are NNOT effective. If you disagree with a position in the proposed rule, explain why you think its a bas idea espeically from the consumer's perspective. Propose an alternative you can live with. If there is something in the proposal you like, for example one of the new proposed disclosures, agree with them on that point. Get your clients to share stories on how YSP made the difference of them buying a home by getting a zero point loan. No One understands our business like we do, so it is our job through the comment period to educate the regulator what we do from the street level. 5) The comment period closes on December 24, 2009 (Christmas Eve). Comment before this date or forever hold your peace. 6) To post your official comment on this proposed rule, go to http://www.federalreserve.gov/generalinfo/foia/ElectronicCommentForm.cfm?doc_id=R-1366&doc_ver=1&name=Regulation%20Z%20-%20Truth%20in%20Lending%20-%20Closed-end%20Mortgages&date=20090723a All comments are public record and MUST be reviewed by the regulators.

I can't believe the continual assault on the mortgage lending industry particularly the provision in R-1366 that limits yield spread a lender can earn. This is a typical Democrat solution that is "packaged" as a proposal to help the poor consumer but will in turn harm consumers by making loans less available and driving smaller lenders who can no longer use pricing to off set closing cost out of business. This is very bad regulation for both the industry and consumer but typical of the Obama administration who is hell bent on moving this country further toward socialism. Here is an interesting concept for the Federal Reserve; LET THE FREE MARKET DICTATE PRICE! I seem to recall that to be a primary function of a Capitalist society.

UNFORTUNATELY too many things (including this) just get slipped by without anyone really knowing, they just worry about the aftermath later. As a 16 year industry veteran in the mortgage industry, the things we are seeing now are unpresidented. WHAT ARE THE CHANCES YOU GUYS COULD GET A NATIONAL PRESS RELEASE ON THIS? They hate media attention, and that's what they need! "Don't steal the government hates competiton" Isn't it great to know they run the banking sector now?

Every LO watching this really has to go to the link below and comment on the YSP issue. I did it already and I read most of the other ones. The sad part is that the congressman voting on this issue will most likely not read any of these. In fact, I would bet that they will not even read the bill before voting on it. However, it is totally unfair to even consider elminating YSP but not do anything about the SRP! The clueless members of this congress have no idea the devastating impact this will have on all mortgage brokers throughout he country. LET THEM KNOW!