- How much is my total payment?
- How much is my down payment?
- How much money do I need to close?
One comment that I would have about the new forms is that they list the origination fees at the top of page 2 in one box. There is no box for lender credits or for adjusted origination fees immediately following the top box as we have today on our forms. At the bottom of the form, there is a box for seller or lender credits. In a lender-paid transaction where the originator is being paid by the lender, this could be very confusing to the borrower, since the lender credit would not appear until the bottom of the form. In a comparison shopping scenario, that could cause the loan originated by an independent originator to appear much more expensive than its bank-originated counterpart.
The origination fee still cannot change and the other fees appear to be subject to a 10% tolerance as they are now. The new form does say clearly in large type that the estimate is only good through a certain date and that after that date it is subject to change.
The two model disclosures are just a first step. After the CFPB gets input from everyone they are supposed to hold round table discussions in LA, Albuquerque, Springfield MA, Baltimore, Chicago, and Birmingham.
Both NAMB and NAIHP have been allowed to weigh in on the new forms, so that is an encouraging sign for our industry. Log on to the link and give the CFPB some input. At least this time, we are all going to have some say in our future.
For related posts, visit www.frontier2000.net.