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Monday, July 29, 2002
Part III
Department of Housing and Urban Development 
24 CFR Part 3500Real Estate Settlement Procedures Act (RESPA); Simplifying and Improving theProcess of Obtaining Mortgages ToReduce Settlement Costs to Consumers;Proposed Rule
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49134
Federal Register
/Vol. 67, No. 145/Monday, July 29, 2002/Proposed Rules
1
The term ‘‘lender’’ is used throughout thisdocument to mean any person who is the ‘‘realsource of funds’’ for a federally related mortgageloan.
2
Except as specifically described in footnote 17,the term ‘‘mortgage broker’’ is used throughout thedocument to mean a person (not an employee of alender) who table funds or acts an intermediary ina federally related mortgage loan. Mortgage brokersthat are the ‘‘real source of funds’’ for a federallyrelated loan are not regarded as brokers in suchtransactions.
3
The term ‘‘par interest rate’’ is used throughoutthis document to mean the interest rate at whichthere is not payment made by the lender to the borrower or from the borrower to the lender.
4
The terms ‘‘consumer’’ and ‘‘borrower’’ are usedinterchangeably throughout the document.
5
The term ‘‘loan originator’’ is used throughoutthis document to refer to lenders and mortgage brokers.
DEPARTMENT OF HOUSING ANDURBAN DEVELOPMENT24 CFR Part 3500
[Docket No. FR–4727–P–01]RIN 2502–AH85
Real Estate Settlement Procedures Act(RESPA); Simplifying and Improvingthe Process of Obtaining Mortgages ToReduce Settlement Costs toConsumers
AGENCY
:
Office of the AssistantSecretary for Housing-Federal HousingCommissioner, HUD.
ACTION
:
Proposed rule.
SUMMARY
:
The Department of Housingand Urban Development is issuing thisproposed rule under the Real EstateSettlement Procedures Act (RESPA), tosimplify and improve the process of obtaining home mortgages and reducesettlement costs for consumers. Thecurrent disclosure requirements underRESPA have not been substantiallyrevised in decades. The currentdisclosures were comprehensivelyreviewed as recently as 1998 by HUDand the Board of Governors of theFederal Reserve System, but theproblems identified then remain.Nevertheless, since 1998, there have been continuing changes in themarketplace, new products, and greateraccessibility of mortgage information viathe Internet, all of which are reducingsettlement costs and, if properlyaddressed by Government, could resultin greater price reductions forconsumers. First, to simplify andimprove the mortgage loan process, thisproposal would address the issue of loan originator compensation,specifically the problem of lenderpayments to mortgage brokers, byfundamentally changing the way inwhich these payments in brokeredmortgage transactions are recorded andreported to consumers. Second, it wouldsignificantly improve HUD’s Good FaithEstimate (GFE) settlement costdisclosure and HUD’s related RESPAregulations to make the GFE firmer andmore usable, to facilitate shopping formortgages, to make mortgagetransactions more transparent, and toprevent unexpected charges toconsumers at settlement. Finally, therule would promote competition byremoving regulatory barriers to allowguaranteed packages of settlementservices and mortgages to be madeavailable to consumers, to simplifyshopping by consumers and furtherreduce settlement costs. The proposedrule also includes proposed, revisedforms and solicits comments onadditional changes including changes toHUD’s settlement disclosure form anddisclosure requirements.
DATES
:
Comment Due Date: Deadline forcomments on this proposed rule,including comments on the proposedinformation collection requirements:October 28, 2002.
ADDRESSES
:
Interested persons areinvited to submit comments regardingthis proposed rule to the Rules DocketClerk, Office of General Counsel, Room10276, Department of Housing andUrban Development, 451 Seventh Street,SW., Washington, DC 20410–0500.Communications should refer to theabove docket number and title.Facsimile (FAX) comments are notacceptable. A copy of eachcommunication submitted will beavailable for public inspection andcopying between 7:30 a.m. and 5:30p.m. weekdays at the above address.HUD also invites interested persons tosubmit comments on the proposedinformation collection requirements of this proposed rule. Comments shouldrefer to the above docket number andtitle, and should be sent to the Office of Information and Regulatory Affairs,Office of Management and Budget,Attention: Desk Officer for HUD,Washington, DC 20503.
FOR FURTHER INFORMATION CONTACT
:
Ivy Jackson, Acting Director, Interstate LandSales and RESPA Division, Room 9146,U.S. Department of Housing and UrbanDevelopment, 451 Seventh Street, SW.,Washington, DC 20410; telephone (202)708–0502 (this is not a toll-free number)or for legal questions Kenneth A.Markison, Assistant General Counsel forGSE/RESPA, or Steven J. Sacks orTeresa L. Baker (Senior RESPAAttorneys); Room 9262, telephone (202)708–3137. Persons with hearing orspeech impairments may access thisnumber via TTY by calling the toll-freeFederal Information Relay Service at(800) 877–8339. The address for theabove listed persons is: Department of Housing and Urban Development, 451Seventh Street, SW., Washington, DC20410.
SUPPLEMENTARY INFORMATION
:
I. Introduction
The American mortgage financesystem is justifiably the envy of theworld. It has offered unparalleledfinancing opportunities under virtuallyall economic conditions to a very widerange of borrowers that, in no smallpart, have led to the highesthomeownership rate in the Nation’shistory. At the same time, however, theprocess of financing or refinancing ahome, which is regulated under RESPA,12 U.S.C. 2601
et seq.
, remains toocomplicated, too costly, and too opaquefor many borrowers. The monies neededto close on a home are a significantimpediment to homeownership, andsettlement costs are a significantcomponent of these costs. In light of theAdministration’s commitment to reacheven higher levels of homeownership,the RESPA regulatory scheme deservesparticular scrutiny and necessaryreform.The current disclosure requirementsunder RESPA have not beensubstantively revised in decades.Although the RESPA disclosures werecomprehensively reviewed as recentlyas 1998 by both HUD and the Board of Governors of the Federal ReserveSystem, the problems identified in thatreview remain largely unaddressed.Recent judicial developmentsregarding lender
1
payments to mortgage brokers
2
(yield spread premiums andother named payments based on borrowers’ transactions) haveheightened the importance of increasing borrower awareness regarding howmortgage brokers are paid and how borrowers can benefit from paymentsmade by lenders based on mortgagesexceeding par interest rate.
3
Some borrowers
4
understand, agree to, andproperly use higher interest rates tolower up front settlement costs. Othersreport, however, that they paidsubstantial origination costs in up frontfees for mortgages and then learned thatthey were charged interest rates higherthan those they qualified for merely tosupport an additional payment to theirmortgage broker.Under the current rules, many borrowers are provided estimatedsettlement cost information on a GFEonly after paying a significant feerequired by a loan originator,
5
whichprevents the borrower from shoppingamong additional originators using the
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49135
Federal Register
/Vol. 67, No. 145/Monday, July 29, 2002/Proposed Rules
6
‘‘
 Junk fee
’’
is a term used throughout thisdocument to mean any fee charged for a service toa borrower that has little or no value in relation tothe charge, and/or may be duplicative, to increasea loan originator
s profits.
7
The term
‘‘
par value
’’
of the loan is usedthroughout this document to mean the principalamount of the loan.
GFE. Also, when borrowers receiveestimated settlement cost informationafter applying for a mortgage, theestimates are often unreliable and provetoo low. Final charges at settlementoften include additional surprise
‘‘
junkfees,
’’
6
which increase the originalestimates. HUD
s current rules providelittle guidance on the standards thatoriginators should be held to inproviding good faith settlement costestimates.By requiring a long listing on the GFEof each estimated settlement charge, thecurrent disclosure fails to highlight themajor costs and seems to lead only to aproliferation of charges without anyactual increase in the work performed orenhanced borrower understanding toassist in shopping for services and guardagainst unnecessary charges. Thecurrent requirements allow anindividual such as a loan originator, tocharge several fees for origination,document preparation, and documentreview. It is difficult for borrowers todistinguish or understand the precisepurpose of these various itemizedservices provided by the sameoriginator. Excessive itemization thusenables originators to charge more thanif the borrower could review and shopthe total origination charges. The sameholds true for title and other third partyservices. The types of fees charged byloan originators, title agents and otherservice providers have multiplied inrecent years making it steadily moredifficult for borrowers to comparesettlement costs.Industry advocacy groups haveindicated that they support betterdisclosure of mortgage brokercompensation specifically and loanorigination charges in general.Consumer groups have called forprotections against yield spreadpremiums that were not bargained for,more shoppable settlement costdisclosures, and much firmer interestrates and settlement service costs.Settlement cost disclosures need to beimproved so that the information theyprovide is simpler, clearer, morereliable, and reasonably available tofacilitate shopping, increasecompetition, and lower settlement costs.Although HUD has called for betterdisclosures in policy statements andopinions, its regulations need to beupdated to establish requirements thatare more useful to consumers.While technology and market forceshave played a significant role inlowering costs in the settlement process,it is not clear that under existing rulesthese benefits are passed on to the borrower in the form of lower settlementprices. HUD
s rules implementingSection 8 of RESPA require originatorsto pass through third party costswithout
‘‘
mark-ups
’’
or
‘‘
upcharges,
’’
 and generally prohibits volume discountarrangements. Many industry andconsumer advocates assert, however,that these regulatory restrictions preventactivities and innovations which wouldlower prices to borrowers. Manymortgage industry providers also reportthat while they follow the rules, they arecompetitively disadvantaged by thosewho do not because of the lack of adequate enforcement by HUD.Specifically, some assert that HUD
sRESPA rules impede arrangements forthe packaging of settlement services,which would allow packagers to drawon their knowledge of the market andfamiliarity with the products offered byproviders of specific services to developlower settlement cost packages for borrowers. They assert that suchpackages would increase competitionand enhance borrower shopping,lowering costs more effectively thanrestrictions against referral fees orunearned fees. In the joint HUD and theBoard of Governors of the FederalReserve System, Joint Report to theCongress Concerning Reform of theTruth in Lending Act and the RealEstate Settlement Procedures Act, (July1998), (hereafter HUD-Federal ReserveReport) both agencies agreed that anexemption should be established tofacilitate the provision of settlementservices and to improve consumers
 ability to shop effectively for a mortgageloan and thereby allow competitiveforces to reduce the cost of financing ahome. HUD-Federal Reserve Report at33. At that time, some settlement serviceproviders claimed that such anexemption would legalize kickbacks andreferral fees. HUD has examined thisconcern and concluded that guaranteedpackaging arrangements should bepermitted in a carefully circumscribedsafe harbor. Deregulation, transparencyand a free market will wring outkickbacks, referral fees, and otherexcesses more effectively than thecurrent restrictions and, for this reason,the establishment of a safe harbor iswarranted. Under this proposal,settlement service providers may chooseeither to operate using an improved GFEdisclosure, or to participate in packagesqualifying for the safe harbor.Accordingly, this dual approach willprovide industry and borrowers alikewith an opportunity to test bothmethods where they should be tested, inthe marketplace, to determine which ismore effective in lowering settlementcosts.Late last year, in Statement of Policy2001
1, Clarification of Statement of Policy 1999
1 Regarding LenderPayments to Mortgage Brokers, andGuidance Concerning Unearned FeesUnder Section 8(b), 66 FR 53052(October 18, 2001), the Secretaryannounced his intention to make fulluse of his regulatory authority toprovide clear requirements andguidance regarding the disclosure of mortgage broker fees, and more broadly,to improve the mortgage settlementprocess to better serve borrowers. TheSecretary has established the followingprinciples to guide HUD
s RESPAreform and enforcement efforts:1. Borrowers should receivesettlement cost information earlyenough in the process to allow them toshop for the mortgage product andsettlement services that best meet theirneeds;2. Disclosures should be as firm aspossible to avoid surprise costs atsettlement;3. Regulatory amendments should beutilized to remove unintended barriersto marketing new products,competition, and technologicalinnovations that could lower settlementcosts;4. Many of the current system
sproblems derive from the complexity of the process; with simplification of disclosures and better borrowereducation, the loan origination processcan be improved; and5. RESPA should be vigorouslyenforced to protect borrowers andensure that honest industry providershave a level, competitive playing field.In accordance with these principles,this proposed rule would firstfundamentally change the way in whichmortgage broker compensation isreported by requiring, in all loansoriginated by mortgage brokers, that anypayments from a lender based on a borrower
s transaction, other than thepayment for the par value
7
of the loan,including payments based upon anabove par interest rate on the loan(payments commonly denominated
‘‘
yield spread premiums
’’
), be reportedon the Good Faith Estimate (and theHUD
1/1A Settlement Statement) as alender payment to the borrower.Additionally, in brokered loans, any borrower payments to reduce theinterest rate (
‘‘
discount points
’’
) must
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