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additional comments on "Lenders’ Jobs About To Get Easier!?!"
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Eliminate the total autonomy of CFPB and institute a panel of supervisors. Make the organization accountable to SOMEONE! Eliminate the waiting periods for LE/CD/etc. The unnecessary waiting periods are costing consumers money and adding to delays in the financing process. BIG: If a bank can come back on an originator for an EPO there should be a mandatory prepayment penalty for the duration of the EPO. If a consumer is not bound to keep the loan; how can/should we be accountable for their actions? Return to HUD. All this would be a good start.
Make the playing field equal…all loan officers are created equal. All LOs should be required to pass THE TESTS. Thus, most LOs will be hesitant to violate the rules…MY LICENSE IS ONE THE LINE!!!
Formerly had 5 loan officers and two locations.Dodd Frank and paperwork nonsense caused us to have to pay people based on w2’s took over values. Gave banks another way to benefit from hidden appraisal management fees. May force us to join a larger firm ourselves which would mean one less option for consumers. Very unfair when the government limits what a functioning business can charge and what they are worth. Does the government tell a bagel shop owner what to make? Do they tell them because they own a bagel shop that they cannot open up a catering business? Success breeds success. I am all for having a central registry to insure that no criminals go from State to State but also for competition on an equal basis. Companies such as Smells Fago should not be allowed to have competition on an unequal basis. They should never be allowed to lie to the public or dial up fake accounts. Seems to me this is fraud.
You know the really bad thing about all of this is ……these rules were already on the books before Dodd/Frank……LOL…They just made them more difficult…..some of the paperwork I do not mind ….after all its just paperwork…But the major concern I have is with appraisals….Im not happy with the present system …before I had very consistent appraisals from around 7 or 8 appraisars …some of the best in my area ..turn times were quick and I could set 3 different appraisals side by side and they would all look pretty much the same…same distance on comps …same overall adjustments …..now ….Most of the appraisars in my area will not work with the big AMCs anymore …so my appraisals vary so much …..adjustments out of whack …comps all over the place ….Its kinda bad when I have received 3 appraisal in the last month that the appraisar did not even use a comp on the same street that sold 2 months ago(one that matched the house) ….This is the big issue in our industry …It costs the consumer more money and their is no consistency of work ….
You are correct, Dennis, most of the rules go way back, and have simply not been enforced over the years. However, this goes for appraisals too. The Interagency Guidelines going way back to 1992 prohibit anyone with a financial bias in the transaction from having any influence on the collateral (appraisal) assignment. That is not going away. Lenders do not need to use AMCs. They can still order their own appraisals, they just need to have a firewall between LOs and appraisers for the ordering process.