Lenders Withhold Disclosures from Realtors

03/21/2016
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A new “TRID-TREND” is for lenders and closing companies to withhold disclosures from Realtors that want to review them.  The reason why is, if an error is found it will trigger a 3 day re-disclosure even if it’s a really easy fix.  The question is, are you seeing this, and another question is do you think it’s right?

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46 thoughts on “Lenders Withhold Disclosures from Realtors”

  1. Jan Dove says:

    It is very unfair for the lenders to keep the disclosure away from the Realtor. Why? Realtors take an oath to be honest and upright with their client "Buyer" and this makes it look like it is the Realtor trying to keep the buyer in the dark. It makes the Buyer distrust the Realtor and it causes them to loose the
    deal they just made and the client "Buyer" looses respect and trust in the Realtor who is not withholding anything from the client that they have uncovered. It is the Lender not the agent who is hiding the disclosure so they don't have to re-do the disclosure when it is found out by the Realtor and their client. This forces the client to get an inspector to find the defect in the home and if it is an expensive defect then the Realtor may loose the client after all the hard work and expense the Realtor went through. If lenders stop working with Realtors then Real Estate and the economy will be the loosers. The lenders gave loans to people before they should not have and now they not giving loans to people they should give them to. It all comes down to all the regulations and the time element
    of what we are all having to do to correct what happened in some of the loan companies before. We as realtors are having to pay twice for what the loan companies did in the past, If we pay out money to get a "Buyer" client through our ads (which are much more expensive than before) and the lender
    keeps the disclosure from the realtor (knowing the "Buyer" client is going to ask the realtor to see it and the realtor, in especially large companies require the realtor to get it signed by both the "buyer" and the "seller" showing both have been treated fairly by the realtor. It also protects the "Broker," It causes us not to be able to sell as much so it backfires on the lender in the long run. Because the realtor can not send them client's ready to buy as easily. Short sales and foreclosures I can understand because it has always been that way. But, when it comes to a regular sale who fills out a disclosure then it should be revealed to the Realtor. They can not expect us Realtors to sign a contract saying we will take care of our client if we are not given the disclosure. I have always tried to protect both the seller and the buyer, but with the system we have now it is really hard to sign your name to an offer you know might not go to closing because you could not get a disclosure before the buyer received his inspectors report. This causes us to loose a lot of our client's no matter how hard we work. I am working 5 times more hours now than I was when I first started because of things like this. Realtors are held to higher standards than agents who are not realtors so now the non-realtor is doing better than the realtor. It makes one think about going back to being an agent and forget about
    being a Realtor. We Realtors pay more for being a realtor than one does for being an agent because we are suppose to have higher standards, but how can we if we are going to be in the dark on the disclosure? If my client goes to a lender I recommend and the lender gets the disclosure and I do not then that can get me in trouble with my client after he finds the defect from the inspector. Why should a seller fill out a disclosure if the buyer is not given the disclosure until after they try to get a loan or God forbid they pay cash on a dud home. Banks are taking over real estate and it is not a good thing for the USA real estate. The job market has had a big roll in the real estate market and it used to be the other way around.

  2. Michelle Fordham says:

    In my state, real estate brokers are responsible for accuracy of items on the settlement statement or closing disclosures of which they should be aware. I have had only two TRID closings so far, and there were errors on both disclosure statements that I pointed out. The closing attorney’s office was able to correct the items in both cases without redisclosure to the buyer/borrower. Generally, the items brokers will correct will not trigger redisclosure. And if any details are wrong enough to trigger a new disclosure period, then everyone will have to wait the three days until closing. I foresee problems where vendors are not paid at closing and sales commissions are unpaid or incorrect all because another set of knowledgeable eyes did not view the documents.

  3. Rob Aubrey says:

    The irony of it all is, the real estate agent is the only person involved in the transaction that ACTUALLY REPRESENTS the buyer or seller.

    In fact in Utah it is the law that I (broker or broker's representitive) review the docs prior to closing.

    So if there is a three day waiting period for certain changes wouldn't it make sense to let us look at the docs prior to disclosing. Duh!

    a·gent ˈājənt
    noun
    noun agent plural noun agents
    a person who acts on behalf of another, in particular.
    a person who manages business, financial, or contractual matters for an actor, performer, or writer.

  4. Steve says:

    Wrong. Correcting errors on a CD seldom require a new 3-day waiting period. New wait period is required only if the APR increases by more than 0.125%. The reason a lender does not provide the CD to a real estate agent is privacy concerns. A borrower can provide the CD to the real estate agents, and many lenders encourage them to do so. But the lender has not contractual relationship with the real estate agents, and obtaining the authorization of the borrower to release disclosure documents to a third party is too much hassle, and one more risk a lender would incur by releasing the documents. So, the borrower can do that, and the lender cannot prevent the borrower from doing whatever he or she wants to do with the LE or CD. Also, the lender generate CD is not a disbursement disclosure and lenders are not concerned about real estate agent fees. Those are irrelevant to the loan, and lenders do not want to get involved in how the seller pays the real estate agents. What the real estate agents should focus on is the separate settlement agreement that is related to the real estate transaction prepared by the settlement agent, and is used to disburse funds. The CD is relevant only to the loan, and will not have the information that the real estate agents are really looking for.

    1. dot says:

      thats not exactly true, not only do lenders make mistakes but some of the shysters make promises that do not end up on the cd, and hope its so confusing to the buyer they won’t notice, but we do…

  5. Cory says:

    Interesting topic. Now I actually agree with the lenders on this. The agents have no need to see a CD – they CD does carry information that really the lender and the buyer should only be the only ones viewing.
    That being said – the realtor should be able to get a copy of a settlement statement from the title company to make sure the numbers are correct. In the state of WI, the standard ALTA Settlement Statement is used. Now – there is no need for the title company to list out the lenders fees on the document (most do because this 2 page document is easier to go over and explain numbers than the 5 page CD) – they can treat it as their own and just put out the information they have – realtor fees, title fees, etc. The realtor can verify their numbers are correct and move forward.
    Now – again – to the fault of many lenders – there needs to be a better understanding of what causes the 3 day period. Changes to the seller numbers would not cause a new 3 day waiting period and if the APR doesn’t change (up or down .125 roughly), the loan program doesn’t change or a prepayment penalty isn’t added in – well then there is no need to wait 3 days – you can re-disclose at the table.
    Trust me – I hate TRID – I think it is stupid and put together by a group of idiots that never went through nor had a mortgage in their lives.

  6. Leigh York says:

    We were warned by our title companies that they would not be able to share the closing statements with us upon TRID implementation. Our state Association of REALTORS immediately produced a form for the buyer to sign giving lenders and title companies permission to disclose specific information, including the closing statements, to the REALTOR. Within a couple of months, the Real Estate Commission added language to the promulgated contract forms. Thus far, lenders and title companies are respecting it and we're not having this issue.

    In my opinion, the biggest issue for consumers is how much the cost of getting a loan has increased. Most loan fees and some title fees have increased to cover the cost of TRID compliance. This new 'safety' for the buyer is very expensive for them.

  7. Your point that the buyer is "too stupid" rings a bell, BUT it is not that they are too stupid, they are generally educated in other areas. That, my friend, is why they hire a Realtor to represent them. I have had this debate (as it has come to be), with my lender many times, and my lender said: "Yes, you are right, HOWEVER, I am more afraid of CFPB than I am of you." The first closing under the new system resulted in an angry buyer because I was not able to review the document prior to her having to sign it to start the 3-day holding period. A $400 error to her! I caught it immediately. It was a misinterpretation of the contract by the lender. Now let's understand this – I do not want to be a lender. It is ever-changing and complicated. I as a Realtor, am supposed to understand the contract. In Texas, the contract and basic Addenda are a minimum of 15 pages. I had my Buyer's Representation Contract signed, and I had my TILA Form signed to substantiate my authorization to perform reviews of these documents. At least (at the moment) no one has accused the Realtor of not representing the buyer's best interests. To have these documents only reviewed by the lender is a little like the fox guarding the hen house if you believe the Frank-Dodd Act proponents.

  8. Joshua John says:

    The CFPB will not allow us to share because of non-public personal information included on the Closing Disclosure. I have consistently let all real estate agents AND buyers know that I personally cannot share the CD with the agent HOWEVER the borrower is free to do so. The borrower does receive the document 3 days prior to closing and they can easily forward that information along to the real estate agent for review and I encourage them to do so.

    So as an agent (or lender!) please encourage this same behavior from your buyers/borrowers!

  9. Have already had that happen. $400 was not found til after closing because I could not review it. My buyer did not get all that they should Now the seller does not want to pay because it was after closing. So sad. If I had been able to review before closing, would have seen it.

  10. Sue White says:

    I think this was a horrible mistake, if you want to call it a mistake. How can we protect our clients, and even our customers, if we don’t know what is going on! I think this should all be reversed IMMEDIATELY! A lot of the attorneys don’t even want to do real estate loans now because of all of the red tape, the times it takes etc. It slows the process down and boggs the system down and clients don’t want to wait sometimes so they just give up. They come to US as brokers and agents for answers and when we cannot give them answers we look like we are not on top of things. I don’t know who dreamed this whole TRIAD thing up, but they need to be fired as far as I’m concerned!

  11. Matt Pfeiffer says:

    I understand what’s taking place regarding today’s show, but what I don’t understand is why the Realtor reviewing the CD would have an impact on triggering a new, 3 day waiting period if something was noticed that needed to be changed. There are only 3 items that trigger a new, 3 day waiting period: 1. APR increase by more than .125% (.25% for ARMs) 2.Loan program change 3. Prepayment penalty added So, most of the time, adding a broker’s file storage or processing fee, correcting tax prorations, etc. would trigger an updated CD, but not a new waiting period. Additionally, what is wrong with the lenders that these types of mistakes are showing up on the form in the first place??? Aren’t the LO’s paying attention to the details of the transaction and the contracts? I could go on…

  12. Leslie De Palo says:

    This is most interesting…others states seem to interpret what is appropriate differently! Being a Loan Officer in California, I share any and all Closing Disclosure numbers / information with my Borrowers AND their Realtor so they can all look carefully at the documents and make sure everything is correct before we go to the final signing. Frequently, I find that the various Title companies make mistakes. My most recent Purchase transaction was rather “strange” because the Realtor (Buyer’s Agent) went directly to the Title Company and wanted to move forward, even though I told the Realtor there were mistakes that needed to be corrected. Apparently, they did not trigger a TRID waiting period!? Anyway, the Realtor wanted to close and did not care, even going so far as to tell me that the “Title Company said it was good to go” and I did not need to be at the signing, which is part of my normal practice. I like to be at the final signing to ensure everything goes smoothly and there are no lingering questions, nor concerns. I let the Realtor know that if I was not able to make sure all the numbers were correct before the Borrower rushed to signing, then I could not be held responsible for the errors. In the end, the Title company was able to fix, correct a couple of mistakes and I can only assume that they did not violate TRID!? My Borrower was happy and the transaction closed within 26 days per the Purchase Agreement. The loan was submitted to United Wholesale Mortgage on February 1, 2016 and closed/funded/recorded on Friday, February 26, 2016. NOTE: This was a 95% CLTV, Lender Paid Mortgage Insurance (no Borrower MI), $417k conventional, Owner Occupied 30-year fixed rate loan at 3.625%. With respect to my newest purchase loan, I can only hope/trust that the Realtor will be concerned that the documentation is correct before signing final loan documents!

  13. Emery Stautzenberger says:

    YES IN THE LAST 45 YEARS, I HAVE FOUND A LOT OF MISTAKES AND GOT CORRECTED BEFORE CLOSING.

    1. Matt Brady says:

      Yes, errors are made. By Lenders, Escrow Companies, Notaries and Realtors. Has anyone EVER had someone cancel a transaction because during a 3 day waiting period? The point is borrowers should be allowed to waive a 3 day wait that could harm them. On refinances in CA it is really 6 days, 3 for the CD before they can sign and then 3 more for rescission. They should at least allow those time frames to run concurrently.

  14. THIS POLICY MUST BE CHANGED SO WE CAN VIEW AND PROTECT OUR BUYERS AND SELLERS. THEY HAVE GONE THRU ALL THE HOOPS JUST TRYING TO GET THE LOAN.

  15. Its warm in AZ this week! You better stay "hydrated." Cheers

  16. YES, I've seen this behavior several times since last fall. I find it annoying that the lenders and title companies are our business partners and want our business before the deal, yet they don't want us to review to be sure all fees and commissions are correct. They'd rather wait until the pressure at the closing table!! So, I've quit using any who have this attitude and they seem to be getting it now. I've also disclosed to buyers and sellers that this exists & get them to sign a form to release the info.

  17. Bonnie Stocker says:

    Why does the realtor not get a copy of the CD? The title closer should be sending these to the realtors just like they always sent the HUD/settlement statement…..

  18. This is exactly the truth. Most clients don't even know that they are paying super high prices for this completely unnecessary 'safety'. I have seen no protection for consumers just the opposite. They have no clue what they are even looking at and we, the architects of the contract, are prohibited from ensuring its fulfillment – what a joke. I have seen absolutely nothing that TRID has fixed, except garner higher fees for mortgage and title companies and keep the poor consumer even more in the dark than ever.

  19. This does happen and it is ridiculous. How do we represent our clients without reviewing the CDs. There are mistakes as they are prepared by humans. SIMPLE SOLUTION THOUGH! Just ask you client to share it with you. They have to have it 3 days prior to closing. KISS!

  20. Margi Popp says:

    TRID is a joke. I am not liking this at all. You all are right, our clients have no clue what they are reading. Closing Statements can be overwhelming and confusing. This is a program that needs to be dismantled.

  21. NANCY VIEJO says:

    Well, see, this is where a very good Mortgage Broker comes into play. I tell every title closing person to send me a copy of the CD before sending it to the lender for approval. When you are to the point of the CD, the lender has all invoices for closing, a prelim/pre final CD from title, the loan is locked and a copy of the real estate contract showing the agent % of commission. What more is there? A good Mortgage Broker will ask the agents if there are any addenduns or changes that affect commission or payments to them or from the buyer and seller. That is done prior to CD release to the borrower. The buyers CD can be changed at closing for any items concerning the agent as long as the buyers funds to close represent an affordable increase. Any of the 3 things that would trigger another 3 day wait would not be ANYthing the agent would even know the answer to. The sellers closing statement is really not subject to TRID so the listing agent can see it anytime they want. I don’t see an issue here at all, but again, most do not use a “good” mortgage broker. Member of FAMP,NAMB, NAPMW, WCR and 2 local real estate boards. Have a great day.

  22. What? You don't think the mortgage person represents the buyer?

  23. What? You don't think the mortgage person represents the buyer?

  24. Rob Aubrey says:

    Todd Schneider

    No!

    Show me the contract that an LO represents a borrower.

    I bet the bank originating the loan has a contract with the LO

  25. Not seeing this in Austin, Texas metro area

  26. We are still closing loans within 30 days or less

  27. Dora Griffin says:

    Rob Aubrey If LO's did not have a fudiciary duty to the buyer then we would not have surety bonds. Mortgage brokers have a borrower broker agreement that describes our duty to the buyer. So, yes, we have a duty to represent what is in the best interest of the buyer. That is why we have a ream of paper and now TRID in our files.

  28. Dora Griffin says:

    I share the settlement sheet with the agents when I have it before closing. The only thing I've run into is the real estate broker wanting to collect a "processing fee" on the settlement sheet. The processing fee is a junk fee to the buyer along with the 3% commission. By it not being on the HUD does not mean the buyer cannot pay for it, they just need to write a check to the real estate broker. It has nothing to do with my settlement sheet.

  29. Rob Aubrey says:

    Dora Griffin , Brokers have become all but extint, my reference was more to LOs working at mortgage banks.

  30. Dennis Mason says:

    Rob Aubrey ….You are incorrect Brokers are making a come back…..and yes as a broker we do represent the borrower to help them meet their financial needs ….they sign a contract with me to that effect that also states exactly what I am getting paid for my services….Besides without the broker/lender and the real estate agent working together as a team and knowing the situation that each particular buyer brings to the table ..we would never get any loans done in this market ,,,that teamwork makes it a much smoother process for everyone…so How can you say we dont represent are borrowers ??/

  31. Dennis Mason says:

    I am sorry to say …..that as a realtor you do not have a license to go over loan documents and it is in the rule…this includes the Closing Disclosure..I would be very careful to not overstep these boundries….This also is true for a lender to go over contracts without a realtor license or being an attorney…It is not fair but it is reality…

  32. Why are lenders disclosing REAL ESTATE commissions and other pieces of the transaction that are not LENDER costs? Then the lender is punished if the costs that are told to them increase? The VAST majority of costs that are disclosed by the lender are not under the lender's control. It's really stupid. Every item on the closing disclosure should be the reaponsibiity of the entity that provides the service. If an XYZ fee goes up, then the XYZ company should be responsible for the increase. Three days to cure these issues is too long. A one business day waiting period is more than adequate for everybody to redisclose the documentation. We're not sending information via covered wagon. This is what you get when you let self serving politicians create laws without finding out what is going on in the real world.

  33. As a 21 year veteran in mortgage business (producing BM), I have not seen any issues with TRID so far. In fact, I think it has made those LO's/companies that werent always upfront with borrower become more accountable and accurate. Yes there we a little growing pain to start, but like everythign else we have a process in palce in things are running very smoothly.
    Every deal I do I request the prelim CD from the title comapny and make a call to both agents for any additional fees such as their "Compliance" Fee, that way they can be added to my initial Loan Estimate when I take the initial applicaiton. I also like the fact that my borrowers, agents and I all have time to go over docs with buyers prior to going to closing table. In the old days everybody wanted a clear to close and then close the next day, sometimes the same day. TRID has made that a thing of the past and I believe it is for the better.
    Bottom line is that if you set the proper expectations upfront, and do a little leg work regarding fees from other parties, then TRID should not be having that big of an impact on your business. Our company fees have not changed at all, only the processes to get file thru the closing department so those that say TRID has increased fees I would ask WHY???

  34. Rob Aubrey Sorry Rob…. you need to wake up. Brokers are and have been making a comeback. Brokers can beat bankers all day everyday on the rates and the service is pretty much on a leveled field now.

  35. Its not that simple…. some fees have different level of tolarnces. so even if you spot an error, there still maybe a cure to someone regardless.

  36. Lilia Rivas says:

    Privacy!!! Privacy!!! If the borrower wants his agent to review the estimated Closing Disclosure then the Borrower should share it with them.

  37. Larry D. Shtes says:

    Yes TRID, CFPB and Dodd/Frank are all idiotic at best. Kristen Leach has it correct. The LO should get the CD as soon as available and call their buyer to go over the numbers before an appointment is made to sign. This eliminates any and all questions/problems at the table. Personally and professionally, after putting dirt and money together for 45 years, I do not understand real estate agents getting involved with my end of the business. Once my RE agents get the P&S agreement signed around, the buyers become MY client. If I need the RE agents I will call them. They need to go sell another piece of real estate not worry about the money, that is my job. If there is a problem with any of my deals I make sure my client is notified then the selling agent. LOs, take and maintain control of your transactions. Drive them do not let them free wheel to the closing table! the road.

  38. Simple solution to the problem "TRID" can adopt, is the error is below 1% or 1.5% of the loan value, the escrow officer can correct at signing and if everyone agree's – deal closes;

    You really want consumer pertection of three days if there is a large error or non disclosure in the paperwork which would be the 3% plus error? give them the option for the three days.

  39. Dennis Reese says:

    Question, when was the last time an error on the CD triggered a new 3 day waiting period? It has to be pretty ergregious error to trigger a new waiting period. 1/8% change in APR, wrong loan program or adding a pre-payment penalty. Errors don't require a new waiting period!

  40. So, a bit wordy, part 2 of 2 parts… but… this is a topic/subject that is near and dear to my heart…

    This is what ECOA says

    4. Timing.
    Section 1002.14(a)(1) requires that the creditor “provide” copies of appraisals and other written valuations to the applicant “promptly upon completion,” or no later than three business days before consummation (for closed-end credit) or account opening (for open-end credit), whichever is earlier.
    i. For purposes of this timing requirement, “provide” means “deliver.” Delivery occurs three business days after mailing or delivering the copies to the last known address of the applicant, or when evidence indicates actual receipt by the applicant, whichever is earlier. Delivery to or actual receipt by the applicant by electronic means must comply with the E-Sign Act, as provided for in § 1002.14(a)(5).
    ii. The application and meaning of the “promptly upon completion” standard depends upon the facts and circumstances, including but not limited to when the creditor receives the appraisal or other written valuation, and the extent of any review or revision after the creditor receives it.
    iii. “Completion” occurs when the last version is received by the creditor, or when the creditor has reviewed and accepted the appraisal or other written valuation to include any changes or corrections required, whichever is later.

    Bottom line for me is that the bottom line is much farther down the page and it would take much longer to really cover this topic than this forum will permit.

    Suffice to say that REALTORS® have a fiduciary to their client. It is our job to help the buyer understand where to get the best information needed for him/her to make an informed decision on every aspect of his/her real estate transaction, to include the loan/lending component. That type of counsel cannot be delivered without a review of ALL of the documents the buyer will sign off on. As a Licensed Real Estate Agent, we do not need to ‘interpret’ the loan documents, but we will almost certainly be able to raise questions about anything that we might perceive as ‘out of the ordinary’ and then instruct our buyer to circle back to his/her lender for further review and explanation. And… it wouldn’t be out of the realm of realty for the REALTOR® to ask to sit in on that discussion/explanation. Heck we might just learn something new ourselves.

    G-II Varrato II is Ret USAF and a Licensed REALTOR in Arizona with 3 decades of real estate experience, and the Arizona State Director for VAREP (Veterans Association of Real Estate Professionals) and the Phoenix AZ Chapter Director of Government Affairs. GVarrato@VAREP.net or G2Realtor@GMail.com

  41. So, a bit wordy, part 1 of 2 parts… but… this is a topic/subject that is near and dear to my heart…

    While TRID may have some challenges, as a 30 industry professional and a Retired USAF Veteran, I can assure you ALL that CFPB has NO restrictions nor provisions that instruct the lender or loan officer to withhold any of the disclosure documents, to include the LE (Loan Estimate) and CD (Closing Disclosure). That notion is purely spun by nervous lender/LOs and/or title companies.

    I instruct our buyer to NOT sign any of their disclosure package until they have discussed, each and every page, with their loan representative, either on the phone, page by page, or in person, page by page. That is a process that is not unlike what a buyer encounters when he/she is represented by a licensed REALTOR® when the buyer signs his/her offer. Further, the buyer agrees to NOT sign off on the LE or the Intent To Proceed until he/she and we have reviewed the LE together and if, during that review, the buyer has additional questions about the content of the LE, we have the buyer circle back to the LO for a deeper explanation of the LE. If at that time the buyer wishes to explore other lending options, under the 10 day period, he/she has to do so and the buyer launches that boat and off they go to secure additional LEs from competing lenders/LOs.

    So at this point you’re probably saying, why didn’t the buyer go ‘lender/loan’ shopping before he/she received the LE from LO “A”. The reason is simple. Any figures, provided to the buyer by the lender/LO on any form other than the LE are not bound under CFPB tolerance rules. The buyer simply doesn’t have all of the information he/she needs to successfully shop ALL of the ‘shop-able’ components of the proposed loan.

    When the buyer finally settles on a loan product and his/her LO of choice, the buyer signs the ITP (Intent To Proceed) or issues the ITP in a format acceptable to the lender/LO. It’s really pretty simple and it has worked well for dozens of our TRID transactions to date.

    To the point of document disclosure delivery; that is where I have a really HUGE problem. Prior to TRID, the buyer never saw these disclosures until he/she was at the title company on ‘loan doc signing day’ and yet today lenders simply send the 30 to 70 page disclosure document package with no follow up contact with the buyer, expecting the buyer to successfully wade through each of the pages and sign off with total understanding. It seems as if lender are looking for a way to ‘confound’ the buyer and overwhelm him/her with dozens of pages of content that are as meaningful as ‘Einstein's Theory of Relativity’.

    Recently we encountered several concerns about how different lenders and builders are applying the concept of TRID. I encountered several instances that I have been directly involved with in both our civilian and our military real estate clients.

    Remember, CFPB intended the LE to be sent to the buyer as a ‘standalone’ disclosure document, not bundled and buried among 30 to 70 pages of additional disclosures. All too often, I see a Loan Estimate that was presented simultaneously which also included a printed “Intent To Proceed”, imbedded in the 30 to 70 page disclosure document set and usually the ITP and LE are nowhere close to each other in the document package.

    Another very dangerous practice of many lenders is to ‘pre-check’ options for the buyer on documents that are loaded into the disclosure package. I have seen numerous iterations of the ECOA disclosure, that range from a simple disclosure of the law and what the buyer’s rights are, with respect to receiving a copy of his/her appraisal to a ECOA form named “WAIVER OF ADVANCE DELIVERY OF APPRAISAL” In the “WAIVER OF ADVANCE DELIVERY OF APPRAISAL” form was written the following, “…I understand that if I DO NOT sign this waiver AND RETURN IT TO THE LENDER, the loan closing may be delayed…”

    For those of you who don’t know what ECOA is, it is the Equal Credit Opportunity Act. ECOA can be a bit confusing thus the Notice of Waiver of Advance Delivery of Appraisals may be a bit confusing for many Consumers, regarding Delivery of the Appraisal.

    CONTINUED BELOW

  42. Brenda Feria says:

    It is the agents' responsibility to have good communication with both the lender and the attorney representing their client as well as the agent representing the other party. Many issues arise because the agents have not done their job – an addendum that wasn't delivered; a warranty program that was not ordered. If everyone has been informed, there should be no surprises on the settlement papers. It is all about communication.

  43. Dennis Mason says:

    Wow………This is a very interesting page….I have made some comments……But the simple fact of the matter is that Realtors do not get a copy of or are shown the Closing disclosure…..Realtor commission is not shown on the CD it is shown on the sellers statement or "Alta Page"….That is why they do not see the CD …as well as the buyer does not see the "Alta Page " either…..This is the way the CFPB has set this up …Not my rules …not my game …I just bring my glove and catch ground balls…
    But my real concern with all the comments is their is a real issue here with trust…..Do all the realtors out their realize that every loan officer is capped on what they can charge ???..their are no extra fees ….their are no junk fees we can charge??/…If are comp is 1% …or 2% …That is it nothing more nothing less ….and a good LO is going to go over the CD with the borrower when it is sent out so not to have any confusion at closing….So what I am reading here is that the Realtors want to see the CD to make sure that no extra fees are being charged etc etc…Not needed anymore….Their are so many checks and balances in the system now …cant happen …..I think everyone needs to take a step back take what has been handed to us and accept it and move on……And give everyone the benefit of the doubt …that the LO/lender …the Realtor… and the title company…no their job and all are working for the benefit of the buyer and the seller……..

    I

  44. Melissa Begg says:

    Todd Schneider hells no! It is the banks that got us into this mess. NOT REALTORS. N

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