tag:blogger.com,1999:blog-9163041974875328406.post3277824405816608959..comments2023-10-28T05:22:35.184-07:00Comments on Paying for Protection: The CFPB Wants to Hear from You--Just Before They Destroy Your BusinessAlexandra Swannhttp://www.blogger.com/profile/02973264059024793128noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-9163041974875328406.post-77506737830170443322012-07-09T14:02:23.710-07:002012-07-09T14:02:23.710-07:00You make a lot of good points. The playing field ...You make a lot of good points. The playing field has never been level and it is less level today than every before. This week I am going to write about the new CFPB proposals again. They are shocking when you consider the impact that this will have on the industry as a whole.<br /><br />Thanks for such thoughtful comments.Alexandra Swannhttps://www.blogger.com/profile/02973264059024793128noreply@blogger.comtag:blogger.com,1999:blog-9163041974875328406.post-25634290942610295882012-07-06T10:25:45.922-07:002012-07-06T10:25:45.922-07:00Alexandra,
Good stuff. Keep it up!
Look at the ...Alexandra,<br /><br />Good stuff. Keep it up!<br /><br />Look at the Gestalt - "organized whole" regulatory trend. Without outlawing the brokering of mortgages, which would be smacked-down in court, the regulators are forcing small independent (non-depository) originators into a depository-esque compensation system. <br /><br />Licensing requirements? If you work for a depository... Name, rank, and serial number input into the NMLS. Check. Go get’em tiger. <br /><br />What if a depository originator wants to come to my shop? Education. Background check. Testing. Fees. Plus… I hope they have some loyal referral partners. And a lot of savings. And 2 or 3 months of fun things to do while on their licensing sabbatical. Or get "creative" with the rules and hope you don't get caught (which would be moronic). <br /><br />All of this is in the name of consumer protection?! Sure it is. <br /><br />Look at the Gestalt my friend. <br /><br />Don't believe me? Look at the most recent regulator PR and rhetoric. Raj Date’s recent comments? Correct me if I'm wrong, but YSP has been credited to the consumer since January 2010? Don’t forget our good friend Jamie Dimon (with his recent ~$9 billion dollar one trade loss) telling the world it was the mortgage broker that damned the world economy… oh, by the way, he forgot to mention that Chase owned 2 of the top 10 subprime lenders. <br /><br />They are killing us with crony capitalism. We can pay our people like banks… basis points. Flat fees. Salary. Hourly. Nothing tied to terms or conditions of the loans (i.e. profitability). <br /><br />Even the current court ruling in favor of the DOL against the MBA (on overtime and hourly wages) coincides with this trend. Pay like a bank and you won’t get busted. <br /><br />Tell me… how can I compete selling a commodity when I can’t lower my fee? What happens when rates go back to 6 or 7 percent? What happens when the market inverts to 80% purchase and 20% refi as a percentage of originations? <br /><br />It’s coming. Well have a bunch of originators scrapping for a finite market share. Purchases. <br /><br />And our competitor, the bank, makes money on deposits, car loans, credit cards, investments. You get the picture. <br /><br />Want an example of absurd? In order to advertise in Angie’s List Monthly Magazine they require us to offer a coupon or discount. We can’t. It’s illegal. We can’t offer a free appraisal or credit report exclusive to Angie’s list subscribers. <br /><br />The bank down the road offers a discount on Angie’s list. <br /><br />Fair? Show me anyone that isn’t a mortgage broker that gives a d@mn. <br /><br />The bank down the road can also lower the borrowers mortgage rate if the borrower agrees direct deposit their pay checks. <br /><br />The bank can match a lower fee. They can give a lender credit on page 1 of the HUD. They can give the borrower a $100 Visa gift card at closing. Put that in your flat fee pipe and smoke it. <br /><br />Sure, maybe we can survive with hard work, and blood, sweat, and tears. But It sure would be nice to be able to compete fair and square. <br /><br />Lastly… why was the compensation rule necessary in the first place? Fannie and Freddie have limited charges to the borrower to no more than 5% for years. Look it up. Investors have capped total yield for years as well (on conforming deals). <br /><br />I know, why not just make a regulation that all YSP is credited to the borrower on brokered transactions? <br /><br />Oh wait… they did. It is the 2010 GFE!<br /><br />Hey…?? Why are they “fixing” something that is already “fixed”...? <br /><br />Perhaps Mr. Dimon suggested the idea when President Obama gave him the presidential cufflinks, he so un-casually displayed at the recent Congressional inquiry err... ‘fund raiser’?Anonymousnoreply@blogger.com