PUBLIC SUBMISSION | As of: November 20, 2009 Tracking No. 803f857c Comments Due: May 13, 2008 |
Docket: HUD-2008-0028
FR-5180-P-01
Real Estate Settlement Procedures Act (RESPA): Proposed Rule To Simplify and Improve the Process of Obtaining Mortgages and Reduce Consumer Settlement Costs
Comment On: HUD-2008-0028-0001
FR-5180-P-01: Real Estate Settlement Procedures Act (RESPA): Proposed Rule To Simplify and Improve the Process of Obtaining Mortgages and Reduce Consumer Settlement Costs
Document: HUD-2008-0028-0005
Comment Submitted by Larry M., Major Mortgage Lender
I'm a Loan Officer with a Major Lender and have been for the last 8yrs. I spent my
first year in the "broker world" and I can attest to differences in both business
segments. I agree that a uniformed GFE or Closing Cost Estimate should be
used. I say this because there is a "vast" majority of the general public that won't
take the time to read or perform any due dilegence prior to shopping for a
mortgage loan. This has always been true and it will remain so. Therefore I do
agree that "some" form of standardization is needed on this document. The overall
disclosure process is an Attorney's dream. This will never be simplified. As long
as attorneys review and have their say in this part of the process....it will "never"
be streamlined. I was "trained" too personally go over these documents with
clients. Some don't require this consultation but the greater majority of most
applicant(s) do. When necessary, I take the time to go over each individual
disclosure with my client and make sure they understand what each disclosure
means before they sign. Again not all clients need this.
I do this for my piece of mind and too provide a high level of customer service for
my clients. It is also "sales 101" ... it helps builds rapport, this leads to better
service which hopefully leads to future referral business from the client and/or the
REALTORS involved. Which leads me to my point.
WE ARE SELF EMPLOYED!!! There are a few loan officers paid a base salary
though only a handful of Bank. This not common.
I personally know many Loan officers in my city, it's a fairly small group overall in
town, who work for other banks and Mortgage Brokers who I consider
independant. The large "majority" of my fellow Mortgage Professionals are straight
100% Commission based employees.
In other words we are self employed.
If we're not getting and "closing" the business then we don't make any money to
feed our families and pay our bills. WE ARE SELF EMPLOYED.
However, since I'm with a Major Company and have a large name behind me, my
employer "keeps" 40-50% of the revenue I generate (the house). ALSO, I'm
capped on the amount of additional compensation I "could" generate through an
origination point.
When I compete with brokers, I seldom charge an origination point so that I have a
chance of capturing that clients business.
Brokers get paid off points and YSP. Brokers and the mortgage bankers working
for that broker, can beat my rate and still make good YSP because of the
Wholesale relationship with a lender......At one point in this business, I would get
beat on a loan/rate by my own company....because a broker was using our
Wholesale rates.
Brokers should not be required to "give" back the YSP. They have overhead just
like any small business.
To regulate and institute "new" laws, requirements, training, etc., etc. is
fine....something needs too be done....and I'm all for it.....BUT, to regulate my
pay. To tell a self employed professional how much money they can make or
cannot make, borders on Socialism.
As a professional mortgage loan officer; it is my responsibility to the
REALTORS, the HOME BUYERS, the SELLERS, (the SELLERS BECOME
BUYERS on another transaction)...it is my responsibilty to make this
process "successful."
FREE of STRESS, FREE of PROBLEMS.
I have many important people "counting" on me to get the transaction completed. I
market to Real Estate professionals on my very "level of service and expertise."
It's what makes me successful. On the other hand, if I don't do these things
successfully with a high degree of service, knowledge, capacity to manage people
and the loan process....then I don't get paid....
Anything can go wrong on a deal and it usually does...it's the mortgage
professional with the right attitude, loan product knowledge and experience that
keeps everyone happy and prevents or minimizes any pitfalls.
If compensation regulations "stiffles" the very nature of commerce...then
eventually every "person" and I use this word....not professional....WILL BE AN
ORDER TAKER.
If you think there's problems "now" with our industry....Just think what you'll get
when your sitting in front of $12/hr bank employee. Yes, eventually this person
could eventually gather enough experience and knowledge to be consider
something of an asset to a REALTOR or Home Buyer.
But I've left out one very important factor to all this. STRESS. .... it must be a
number like 95% - 98% of all current mortgage professionals.... WE Live off the
STRESS... WE Live with the STRESS... WE manage the STRESS....WE
FEAST off the STRESS....>>>> HOW??? WHY??? >>>
Because, Not on Every Deal but on some, if we do a great job and our Clients are
willing to pay for our SERVICE, our KNOWLEDGE and our EXPERTISE....>>>
Then we can make some money. Just like any self employed person/business
sets out to do. Take that away and many will leave the industry and with it will go
the SERVICE, the KNOWLEDGE and the EXPERTISE....that so many
REALTORS and HOMEBUYERS have been counting on for years and years.
I'm said my peace. Thank You. Larry M.