I teach a class called “RESPA” which is about the federal Real Estate Settlement and Procedures Act. This act has been around since the mid-1970s and the industry sometimes refers to it as the anti-kickback legislation although RESPA does much more than that. Sections 8 and 9 of RESPA prohibit exchanging something of value for a referral of a federally related loan. The industry went through a wave of federal consumer protection legislation during the 1970s when we received the Truth-in-Lending Act, RESPA, ECOA, and the Fair Credit Reporting Act. It is my opinion that the mortgage lending industry should not be surprised to receive no less than four new federal laws during the next 7 years.
In order to truly understand the spirit of RESPA, let’s take a trip in the way-back machine and visit the 1970s. We had an oil embargo, inflation, rising unemployment rates, a recession, and other events I was too little to recall, but I’m sure our readers will help us remember. I DO remember sitting in line at the gas station with my dad. Times were economically tough for American families. Politicians like it when homeownership rates are increasing because homeownership supports the economy in many ways (and boy are we ever going to learn that lesson during the next decade) and economic growth is good for re-electing politicians. I know I’m grossly oversimplifying here but back in the 1970s, it was important to promote homeownership. Since costs were rising for families, this included the cost of buying a home. One of the main reasons we have RESPA is to help keep the cost of buying a home affordable by eliminating “unearned” fees such as kickbacks.
Sections 8 and 9 of RESPA say we are not to give or receive an item of value in exchange for a referral of a federally related loan. We = any person that earns a fee on the sale or refinance of a one-to-4 family, owner occupied, federally-related loan. Realtors and mortgage lending workers have tremendous power to influence the direction of business for third-party vendors to companies such as title insurance, escrow, home inspectors, home warranty, hazard insurance, private mortgage insurance, appraisers, attorneys, and so forth. For example, title insurance companies do not chose to spend their advertising dollars on general public promotions because a title company can have a much stronger effect on market share by focusing on the people who are in a direct position to refer lots of business: Mortgage lenders and Realtors.
Handing out normal promotional marketing material is considered acceptable under RESPA. What’s not acceptable is to promise something of value in exchange for a transaction. So let’s see, what season is it? Baseball. Here is an easy example: A third party vendor offers opening day box seats to a Realtor or mortgage lender in exchange for a referral of a federally related loan. Just say no. Both the giving and the receiving party would be violating Section 8 of RESPA.
HUD asks us to consider who is paying for the box seats. The answer is the consumer pays, in the form of higher fees from your vendors. The true spirit of RESPA is to keep settlement costs down in order to help make homeownership affordable.
Title insurance companies in Washington State were given a major public spanking at the end of 2006 and then again in 2007. Title companies were violating a not-well-regulated “Only spend $25 per customer per year” rule. Some of these insurance commissioner cases are still pending. The $25 per year rule is a state Insurance Commissioner rule but it also bumps up against the provisions of RESPA.
In their defense, title companies pointed the finger at affiliated business arrangements (AfBAs), legal under RESPA. AfBAs, also known as Controlled Business Arrangements (CBAs) say that a mortgage lender or a real estate broker can open up affiliated businesses in order to continue to grow profits. Examples in WA state are: Windermere Real Estate and Windermere Mortgage. John L Scott Real Estate and Response Mortgage.
Along with the affiliated mortgage companies, a group of Windermere broker/owners owns Commonwealth Title and Escrow. John L Scott and Coldwell Banker Bain own Rainier Title and Escrow as part of a joint venture. AfBAs and CBAs exist all over the United States.
Affiliated Business Arrangements are perfectly legal under RESPA, provided the companies all follow a long list of requirements. AfBAs/CBAs have come under scrutiny in several states during the bubble years and title companies nationwide have paid out millions of dollars in fines to settle these suits while “admitting no wrongdoing.”
AfBAs/CBAs are under scrutiny in Washington state now because of the title insurance commissioner smack down. The other title companies are trying very hard to help the insurance commissioner understand that it is difficult to compete on a fair and equal playing field when your competition is being handed title and escrow business by real estate offices.
Here’s how this goes down. A real estate broker/owner owns a percentage of interest in an affiliated title insurance company. That broker/owner has power over the real estate agents when it comes time to negotiate annual contracts. An agent may be offered a better commission split with his or her broker when that agent refers more business to the broker/owner’s affiliated mortgage, title, or escrow companies. This offer is done behind closed doors, sometimes only verbally. The “better commission split” equates to an “item of value.”
Top producing Realtors and Realtors with a set of balls or ovaries call their own shots with their brokers. So this problem mainly affects medium to low end producing real estate agents, which, let’s face it are the bulk of the real estate agents out there.
An obvious solution, if I were a title insurance company sales manager, would be to send my sales force out to work with only top producing Realtors. However, this will require that the title insurance company have a very, very high quality title and escrow interal staff. This is easier said than done. Title companies that put their money into recruiting exceptionally top-notch internal staff tend to grow market share slowly and steadily. Yet even these companies have had a difficult time competing with real estate broker owners who strong-arm their agents into directing title, escrow, and mortage business to the real estate broker’s affiliated companies.
Many have tried to reform RESPA. Many have failed. That’s where the states have taken over. State Senate Bill 6847 passed the state house and senate and has been delivered to Governor Gregoire for her signature. From the bill:
A real estate licensee or person who has a controlling interest in a real estate business shall not, directly or indirectly, give any fee, kickback, payment, or other thing of value to any other real estate licensee as an inducement, reward for placing title insurance business, referring title insurance business, or causing title insurance business to be given to a title insurance agent in which the real estate licensee or person having a controlling interest in a real estate business also has a financial interest.
Apparently the Deparment of Licensing is going to help the Office of the Insurance Commissioner scrutinize the relationship between the real estate broker/owners and their affiliated title insurance companies. Broker/owners with nothing to fear would surely welcome any increased scrutiny.
Consumers reading this blog, a red flag for you to watch for is if a real estate agent or mortgage lender strongly insists on using a specific third party vendor. Ask the following question: “Can you please tell me exactly what you are receiving in exchange for me selecting this vendor?” If the answer is “Nothing,” ask to have that put into writing.
Reputable lenders and Realtors select third party vendors because their rates are low and the service is consistently exceptional.
Not only does strong-arming raise red flags when it comes to RESPA violations, it’s also a red flag for possible mortgage fraud.
I would like to return title insurance to the days where Realtors and lenders selected title and escrow companies because the companies offer great rates, awesome service, and maybe a pen or a notepad. Title companies reading this: That means the money you’re saving by only spending $25 per year per client can be re-allocated towards hiring exceptionally high quality internal staff and less on beautiful hotties to distract the Realtors and lenders from the fact that your internal service is subprime.
Well, unless the title rep is really hot. Exceptions must be made in some circumstances.
My title rep is NOT hot…at least I dont’ think so (I hope he’s not reading this!). For me it’s about the Title Officer and the service. My title rep has asked me if I need any assitance or help…the answers always “no” but this is because of the service I receive. With that said, my husband does work for a title company. However I would not use the company he works at IF the service was not there.
This will be very interesting to watch how the new legislation pans out. As a former title rep, I was discouraged or banned from offices once the ABA’s really came into place. Even top agents would follow their broker–anything to keep their desk fees and other costs down.
I’m glad this is happening. Who a consumer uses for title, escrow or mortgage should not be about what puts the most money in the agent or brokers pocket…and these ABA’s have been big money for brokers. Like you said, Jillayne, it should be about service.
I would love to see more title companies advertising directly to consumers.
Great post! Worth the wait. 😉
Hmmmm…..
Aren’t Commonwealth Title and Rainier Title just another way of saying LandAmerica Title?
Hi Greg,
Here’s the greater Puget Sound/Seattle area breakdown:
FIDELITY TITLE
owns…
Chicago Title
Ticor Title
FIRST AMERICAN TITLE
owns…
The Talon Group
Pacific Northwest Title
LAND AMERICA
owns outright or insures their policies via a franchise agreement (in title insurance lingo, this is called an agency but this might be too confusing for people who would normally associate that word with real estate agency.)
Commonwealth
Transnation
Rainier Title
Lawyers Title (renamed Rainier recently.)
and the new Northpointe Escrow and Title company
On their own:
STEWART TITLE
OLD REPUBLIC TITLE
Thanks, Jillayne
It seems the title companies have long arms and tentacles.
One of the ways to clean up residential real estate is to prohibit any joint ownership. If you are a Realtor, sell real estate – not mortgages and title insurance. If you are a developer, build houses – not finance them. They need to get rid off all these sham affiliated business arrangements.
Hi Russ and readers,
As a business owner, I believe we should leave the provisions for AfBAs and CBAs alone
The problems arose when HUD didn’t set aside any funds to REGULATE Respa way back in the 1970s. They just anticipated that all of us would comply.
It has only been recently that HUD has stepped up enforcement.
Without enforcement, a law is meaningless.
Without funding for enforcement, efforts are dilluted and the FBI ends up going after only the most egregious cases of RESPA violations.
Keep RESPA but enforce it by way of asking the existing businesses to pay MORE money in fees that would go into a fund for enforcement.
Yes, I know, these costs get passed on to the consumer.
Corporations are far better off self-regulating instead of letting the government do it IF it is true that higher fees/higher costs to the consumer are the issue.
Another method is industry self-regulation but the American Land Title Institute (ALTA) has been very lax on self-regulation. My guess is because of all the money being made off of AfBAs/CBAs.
Maybe corporations are happy to have government regulations because the chances of being caught are so low and the fines so nominal that from a business perspective, it makes sense to violate the law, pay the fine and move on.
Rhonda,
Maybe someone at the very top at Talon is deliberately sending you a title rep that is not hot.
When I started in the business an agent typically received $50 or so for placing a Title Order. AfBA’s were pretty much unheard of at the time.
One day a disgruntled Title Employee went to the Powers That Be to “Blow the Whistle”. The RE Companies got wind of it and scurried to buy an interest in the Title Company, as apparently there was no harm no foul for “owners”, only for non-owners.
By the time the investigators came around there were no fines, as all of the companies owned an interest in the Title Companies they used.
From my perspective and recollection, that was the Birth of AfBA’s. Just a bit of history…and that was 15-20 years or so after RESPA was instituted.
Ardell, was that here in Washington? I’ve been an agent here since 1983, (I was 12) and have never had anything like that offered, nor wanted it offered. In the olden days when I actually went to the office, our title reps brought cookies, halloween candy, and sometimes corny little greeting cards with candy or a coffee coupon inside, but no money. Were they hot? Uhhhhhh, I don’t think so, but I guess I’d better say YES so I don’t hurt anyone’s feelings :-)!
I think all of us like to deal with professionals from the simple point of view that it’s always a reflection on ourselves as to who we are doing business with. Work with the best is the only way that makes sense.
Maybe I just operate in a different world than some. I believe in service, I believe that my client wants to talk to me 99% of the time, not an assistant, and I believe if I deliver a quality transaction, the client will refer their friends, relatives and themselves right back to me when it’s time to buy or sell.
And, while I may or may not always choose to do business with our company’s affiliated vendors, I also feel they are extremely qualified, and feel very comfortable recommending them to my clients. To me, it matters not ‘who’ they work with, but how they do the job.
I think as professionals it is also our duty to recommend good vendors for our clients to work with. We are the experts who deal in the business of real estate every day, and part of our job is to make sure the details get handled correctly, honestly, and at a fair price.
As an analogy, when my doctor asks me to use her office’s medical imaging department, I have no problem with that. I know I could choose to go somewhere else, but I trust her judgement and her honesty, and having that service that she knows and trusts, makes my schedule run easier.
“To me, it matters not ‘who’ they work with, but how they do the job.”
Leanne, do you remember about when you first had an in-house AfBA relationship with ancillary services? Seems to me these all formed after RESPA, and were instituted for RE companies to be able to receive the legal form of kickbacks.
As it was explained to me many times, the idea of RESPA is to be certain that agents aren’t under a feeling of obligation to any particular service provider. That’s why they have the “no-kickbacks” rule. Maybe they are great today and yesterday, but RESPA was instituted to be certain that if they went through a mass exodus, weak slump or lost their best people all of a sudden, agents would be able to move freely to a different best for client without a sense of obligation or pressure of ANY kind.
In that light, AfBA’s seem to break the heart of the rule if not the letter of the law, by definition.
The bigger problem is that it makes it very hard for companies without a direct ownership interesty by RE firms to get business, and so blocks open and free business practices.
No, it wasn’t WA, but there were National RE companies involved, or at least independently owned and operated franchises of national companies. So the practice would have spread across the nation fairly quickly.
Even way back we were never pressured or even directly asked to use our affiliates. They were introduced to us (we already knew them), and we were told we could always use who we wanted, and encouraged to get to know the individual, and to decide for ourselves if the services were what we wanted to offer.
How does it make a smaller company more difficult to get business?
I doubt any agent would admit on a public blog that their broker is pushing the ABA title, escrow or mortgage company on them.
Jillayne, you could be on to something about my title rep! 😉
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Ronda, was that a snipe? directed at me??
Leanne,
Rhonda doesn’t aim snipes at people 🙂
I think that the mortgage and escrow people are frustrated because they get “shut out” of the offices. Even if you are not pushed to use the in house people, the offices often won’t let anyone else inside. That’s the complaint I have heard from most Title Reps and Lenders. They can’t get a foot in the door.
I’m sure no one pushes you to use certain services, but I’m also sure that they try to control the info available, especially to newer agents.
Not saying that’s wrong. Nothing irks me more than when a new agent doesn’t follow my recommendations as to whom to use, but then wants me to bail them out when they choose someone who sucks 🙂
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Hi, Jillayne: It’s apparent that HUD and the “powers that be” are giving ABAs a chance to embrace the intended legal structure. Looks like they’ve tossed the ball to the states to deal with shams until and unless HUD can get legislative relief for improved enforcement.
I still don’t prefer affiliations as I believe they create a slave/master relationship between providers and virtually no competition for the benefit of the consumer.
My hope is that the last year has raised the awareness of consumers and new marketing directed to consumers will overcome the referral network lockdown of ABAs.
Leanne, not at all. I’m glad you’re participating in the discussions here at RCG. I wish more agents would do the same…including those who are having their brokers lean on them to use the ABA companies. I don’t think we’re going to see their comments here.
You have your experience–it’s great your broker is allowing the agents to work with their own teams without their influence. This is not how it is at many of the larger real estate companies that Jillayne has mentioned in this post. I know this from 14 years in the title biz (pre lending) on how much things have changed and it had nothing to do with restricting reps from “going back”. The offices I once called on were selective in who were allowed back…I was one of the few allowed. It all stopped with the ABA’s… my best office wanted me to become or work for the (at the time) proposed ABA… I refused. I’m too independent. I was then no longer “allowed back”.
We’re not pressured to use our affiliated mortgage broker, and in fact we haven’t. Nothing against them, more that we really like the ones we do use. If that changes, we’ll probably add them to the mix.
On the insurance commissioner crackdown, the title companies are probably laughing all the way to the bank on that one. We never did get much from them (addresses, hot-dogs, etc.) so I sort of feel like we missed out! 😀
Leanne, why don’t you ask your fellow Windermere agents from Windermere Wall Street or Windermere South about their ABAs.
Kary, I bet you’re right! When I became a title rep back in 1986, things were just starting to dramatically change in the industry…the “party” was over.
One benefit from the ABAs is that when brokers ask those of us who are not a part of an ABA to sponsor golf tourneys, participate in their causes, etc… we see less need to. Why support them when you’re not given a fair chance to compete for business? Now, I believe title companies are restricted from that regardless.
Rhonda, one of the reasons I don’t work ‘at’ my office is due to too many people wandering the halls that I didn’t know, and that I didn’t particularly want to know. I don’t like being approached in my own workplace, so I moved my office home. It is much better!
And, in the 1990’s after a couple of purse & laptops went missing (we believe the person was just someone who boldly walked in, but no one approached him, thinking he was someone’s client!!) our office instituted a policy where lenders, title people, inspectors, whoever, could leave flyers for agents in their mailslots, but not ‘wander’ thru the halls. They could ask if an agent they knew was available, and meet with that person if the agent wanted to see them. Even those we all knew were not allowed the freedom they had previously. A tray of cookies however was/is always allowed to get put in the kitchen!
I have no idea what other offices have as a policy, but certainly feel that any business should be able to leave flyers in our agent mailslots at any real estate office. I also do not believe in unsolicted email newsletters or advertisements, but that’s an entirely different matter. I hate those online flyer services!
I think the best way for loan reps or other industry vendors to meet agents is to teach some buyer and seller classes, along with a couple of agents, title reps, inspector, insurance agent, all the players. Or, after a transaction closes, call the agent you didn’t know, and offer to meet for lunch, or just put them on your mailing list. But, the old “walking the halls of real estate offices” shouldn’t be the way to success.
I started working exclusively from home in the early 1990’s, and without all the distractions, my business soared. Plus, I didn’t have to endure 520, and I will do anything to avoid being on 520 in the morning! I now have a place on Whidbey, and I can get to Seattle faster from Whidbey than Seattle to Kirkland on 520 … 🙂
Great post on a topic that is misunderstood by the public and many RE professionals alike.
In my view, ABAs are one of those unintended consequences that regulators neglected to think of. On an economic basis, there isn’t much difference between a realtor getting a referral fee when he sends a client to a lender vs. receiving dividend income through an ABA set up to handle loan referrals. The income is not technically a kickback, but it certainly carries some of the same incentives as one. I know HUD theoretically is opposed to ‘sham’ business arrangements, but as Jillayne has noted, enforcement actions are few and far between.
You can argue that good working relationships (with or without ABAs) between lenders, title companies, appraisers, and agents helps consumers. However, it is presently difficult for the consumer distinguish between a referral that benefits him vs. his agent.
Lending referrals from agents through ABAs are particularly tricky. In my experience (in CA), the loan products offered through traditional RE brokerage houses are fee-rich and have higher rates. Even if agents are careful when making a referral (“Why don’t you talk to our in-house loan guy to see if he can match your rate?”) how many agents fully disclose when they personally benefit from the referral?
Leanne, the “roming through halls” is not the point…and not what I used to do. In fact, when I’m in my office, sometimes I’ll keep my door closed if I don’t want to be interupted by title reps, wholesale lenders, etc.
I’ve heard of brokers checking to see logos on title company envelopes (commitments, listing packages, etc.) and if it wasn’t the ABA brand…the agent would be leaned on by the broker.
I know of title reps who have offered to provide classes and education to companies with ABA relationships and they were flat out turned down by the broker stating…we have an ABA…
I am all for competition and consumer choice. ABAs take away both. I don’t see any benefit for consumers…it’s just good for the brokers pocket book.
ABA’s violate the intent of the law. The worst are developers and their in house mortgage companies. What buyer is going to turn down “free incentives” of $30k in upgrades if they use our preferred lender? No one…even if the mortgage is legal loan sharking.
None of the major real estate agency here in Chicago with front ABAs for Wells Fargo and GMAC will let independent brokers in their offices. That alone should tell you where their motivations are…
The problem with ABAs is that they remove multiple layers of objectivity and protection in a high dollar purchase for consumers. If the Realtor, lender, and title company are all under the same umbrella, who is going to speak up for the buyer?
What I find ironic is that before ABAs, brokers would preach handing out three cards to protect the agent from steering…now, steering to their own ABA is no problem!
Lax, there are some companies that the agent can also be the lender, which in my opinion is a huge conflict of interest. I am not aware of any agent that can take a fee of any kind from a lender, title rep, or whoever for referring business. Our Windermere ABA relationships do not pay us anything when we refer a transaction to them. In fact, I’ve never had anyone in any industry affiliated with real estate offer to pay me any kind of bonus, commission or referral.
Rhonda, companies of every industry will always find companies they want to have a profit/affiliation relationship with. It’s not new, and not just a real estate industry scenario. It can be a good thing in many ways, both for the consumer and for the businesses. Partnering-up is a significant part of many businesses, worldwide.
Rhonda, now that the market is no longer running at the fast & furious speed of pervious years, I’ll bet there are many broker-managers out there who would welcome some training classes/seminars for their agents, ABA or not. And, if not, then offer those same classes/seminars at your own office. I think we’ve got a HUGE need in our industry to help teach agents who have never seen a “slow” market learn how to work with sellers and buyers, in new ways, and I think lenders can definitely teach agents a lot in our current market.
As you know, good clock hour classes are sorely needed, and the market is a-changing, and I think a new, updated financing class is needed. Especially some on FHA — I think we’ll be seeing lots of FHA loans, and I’ll bet if you start asking agents they will mostly all tell you ‘I would NEVER do an FHA loan’, which shows the lack of knowlege out there …
I just closed an FHA loan on Whidbey. Very nice house, $250,000. For real, $250,000. Buyer was able to close in 3 weeks, the FHA appraiser was a little rusty :-), but we got thru that too. 3% down payment, and a very thrilled buyer who works in Seattle, and will ride the bus for work. The FHA loan limit in KC is what? $587k?
That’s going to mean a lot of buyers can afford to buy FHA instead of not being able to afford to buy with conventional loans don’t you think?
And, Lax, no dividend income either …
Just curious, Leanne. What do you mean by clock hour classes? I hope ou aren’t suggesting that lenders or tiitle agents provide free CE credits.
The interesting part of this conversation is the real estate agent point of view that they own the point of sale.
Rhonda, you do a wonderful consumer facing web marketing approach.
I’d sure like to see more lenders and title agents making the move to reach consumers before they select their real estate agent.
It’s a much better use of my time to teach and empower consumers than to fight for the agent referral. Real estate agents and lenders who make selections on quality will refer their business our way. Those that won’t, for other considerations, won’t. Why should I ignore that potential market? I can reach those consumers without the referral.
As I understand the intent of RESPA, which was enacted in 1974, was was to protect consumers during the home purchase process against unnecessary fees and require disclosure of relationships between lenders and those referring them business. RESPA specifically said that no kickbacks or unearned fees, and no referral fees could be paid. Gifts were ok, but could not be gifted for a referral. The purpose of the no kickbacks, unearned fees, referral fees, gifts is from the point that these unnecessarily increase the buyers closing costs. I agree will all of that, and further, I don’t believe that the ABA relationships I’ve seen in the industry within our company violate any RESPA regulations.
RESPA is all about disclosure, and I think we all agree that disclosure is critical. RESPA requires the use of the HUD-1, the GFE Good Faith Estimate, the notices of the servicing of the mortgage, if servicing can be sold, and more. We all like, and should like, RESPA.
Obviously there have been many cases where RESPA has been violated, and here is an article from today showing that even the enforcer of RESPA, HUD itself, has violated RESPA! Ooops!
http://realtytimes.com/rtpages/20080311_respawatchdog.htm
Does that mean that you DID intend that lenders and title agents should provide free CR credits?
Diane, my point about clock hour classes is that an experienced teacher is extremely valuable. The more classes a skilled practitioner can teach, the more skill she/he passes on; as well, the more likely a future client referral.
And your point about reaching agents, lenders and buyers thru being quality oriented is the exact right way in my view.
Advertising directly to the consumers likely just means the consumers cost for title goes up. As Kary mentioned in his post above, many of the title companies do business under several franchise names. His example for Land Title gave 7 different names … how expensive would it be for Land Title to do major consumer advertising for these 7? Would the consumer be better served? Not likely.
The age-old argument is that the agents deal with the title reps, lenders, escrow etc. day in and day out. The agent should have many annual, monthly or daily points of contact with these companies, and hopefully some knowlege of what they actually do.
A consumer who only buys or sells 2 or 3 times in a lifetime would have no way of really knowing ‘who’ is good from even the largest media blitz of advertsing.
The same for lenders. We all hear the constant ads for lenders, but big ad budgets do not translate well into proof of skill. I want to KNOW the loan, title, escrow, inspectors!
Let me rephrase the question. Do you believe it is OK for a mortgage lender or a title company to provide FREE CE credits to real estate agents?
Ok…..well, let’s go here, then.
You said, “Advertising directly to the consumers likely just means the consumers cost for title goes up.”
I find that advertising directly to consumers is the same or less expensive than spending time and effort and money courting real estate agents and lenders. It’s more effective, too, because the consumer is ONLY concerned about the quality of the transaction and the price they have to pay.
Lax wrote: “Even if agents are careful when making a referral (
Diane wrote: “I’d sure like to see more lenders and title agents making the move to reach consumers before they select their real estate agent.”
I think a lot of lenders do, but I’ve never seen title companies do that. Quite frankly, I don’t think they have a lot to offer at the consumer level.
I mentioned above that they’re probably laughing all the way to the bank with the insurance commissioner cracking down. What I meant by that is I don’t think that fees have gone down (maybe they have and I haven’t noticed), so their profits will have increased. If they start going after consumers the only thing they’d have to offer would be price, and in the long run that would hurt them.
When it comes to title and escrow, it’s probably better to leave the selection to the agents, because the agents are the ones that have experience knowing who does a good job, and the title and escrow people want to do a good job primarily to impress the agents. Losing a consumer’s future business would hardly hurt them at all.
In this regard I mentioned in another thread that we left a title company after they wouldn’t agree to remove an item that they agreed wasn’t a lien (due to the homestead law). They would have been better off just paying the item since they’re now losing more revenue each and every month than the amount of that item. Clearly there was no reason for them to do that, but they should have removed it.
Diane wrote: “I find that advertising directly to consumers is the same or less expensive than spending time and effort and money courting real estate agents and lenders. It’s more effective, too, because the consumer is ONLY concerned about the quality of the transaction and the price they have to pay. ”
With the $25 per agent limit, probably going after agents is a lot cheaper. Advertising to mass numbers of people is fairly expensive.
And again, I don’t think consumers can judge the quality.
But I do agree that advertising wouldn’t necessarily drive up costs.
Leanne said: “Our Windermere ABA relationships do not pay us anything when we refer a transaction to them. In fact, I’ve never had anyone in any industry affiliated with real estate offer to pay me any kind of bonus, commission or referral.”
Does your employing broker gets some kind of benefit/share of the profits? If not, what’s the point of the ABA?
Kary said: “I think most firms have an addendum which discloses the relationship when it’s being used. Whether that’s adequate is another matter.”
Good point. I’m not sure what the solution is; I don’t think adding one more disclosure requirement would not do much good even if it explicitly spelled out the ABA details to the consumer. There are already way to many disclosures and it’s hard to believe another would add much.
I frankly think Fidelity has made the move to market directly to the consumer with Cyberhomes. All the rest of us little guys can do it, too, but on a scale matching our size. If a title agent is free to choose, the cash you give up in the ABA is far more than the cost of direct advertising and you are your own master.
Laxtosnoco asks, :Does your employing broker gets some kind of benefit/share of the profits? If not, what’s the point of the ABA?”
Let’s say a group of real estate brokers decides to create a joint venture and invest in opening up a title insurance company. This is not cheap. I believe it costs several hundred thousand dollars to buy into the title plant here in the greater Puget Sound area. So a group of RE brokers pool their funds and then decide how to split profits. Let’s make it easy: There are 10 people in the partnership they make equal investments in the operations and decide that each investor will own 10% of the company.
At the end of the month or quarter or whenever, the group sits down and figures out the profit margins after all expenses are paid, after money goes into whatever capital accounts, and so forth. Then each RE broker would be able to receive profits only up to whatever percentage of ownership he/she has in the AfBA. 10% ownership? 10% of the net profit.
The more business referred to the affiliated title company, ideally, the larger the profits to divy up.
We could do a blog post every week on different elements of RESPA for an entire year and not even get through half of the statue.
The problem here isn’t AfBAs, it’s enforcement of the provisions that HUD set forth in allowing AfBAs. Enforcement at the federal level has been non-existent until about 3 or 4 years ago.
In regards to Diane’s comment #40, now I have an idea for another blog article. Thanks a lot you guys. Here I thought it was going to be an easy week.
Interesting conversations.
If title companies were to market directly to consumers, and they should, the costs to consumers should DECREASE (as my fellow colleague Diane Cipa suggests), not increase. Right away, there would be no need to pay for title reps who receive compensation and benefits from the revenue of issuing a title policy. Google “title insurance in Iowa
Gee, does anyone remember a time when we didn’t care about the brand name of a chip inside our computer? Branding, even when there is little difference between providers, effectively done, causes consumers to choose.
I argue that in my market there is a discernible difference between providers. For instance, I use on staff closers with lots of experience. We close 8 to 8 Monday thru Friday and 10 to 5 on Saturday. We go to a location of the consumer’s choice. All this and we don’t charge extra for the service. Almost every competitor we have either does not provide the service or charges extra or uses a notary signing agent.
Whether you are affiliated or not, I believe the future is consumer faced marketing.
Title companies have so many brands just to try to gain marketshare. I was one of the first four employees hired to start a local title company in King County: Washington Title Company (since absorbed into it’s primary u/w) Ticor, which was a brand of Chicago Title (before Fidelty bought CTI). 🙂
Leanne,
Why would I do classes in a Windermere who has a mortgage ABA if they are not going to allow me the same access or support as their in house lender? I’ve done that song and dance before (I was a clock hour approved instructor for WA state) and now have better uses for my time.
To me it’s no different than when the broker has the agents who work with call and ask for donations or to sponsor golf tourneys…only to not allow the same access to agents as their ABA. No thanks. I have better uses for my money.
I do have an FHA class that I’m working on that will be open for all agents who are interested. I work with agents not offices.
BTW the FHA limit (thru the end of this year) in King County is $567,500.
I would consider helping out with classes at a RE office depending on if I believed I would have a fair chance to gain new relationships. (Thought I should rephrase or add this to my last comment now that I’ve had a little coffee!).
I’m not really in a phase with my business where I’m trying to blindly recruit agents to work with. I have added agents as clients, they are usually more experienced and seek me out. I do welcome the opportunity to work with more agents.
For title reps, its different. I was prettly lucky as a title rep as well since I was “seasoned” and worked with excellent agents…many who still do work with me as a lender.
However in general, most title reps need to call on offices; lenders don’t really need to.
Tim wrote: “The problem with advertising directly to the public is that it is hard enough for agents to differentiate among title firms (especially when the same company has different local nameplates all operating under its umbrella) so how could a consumer differentiate when they only need the service or policy every so often? (actually I take that back when you consider all the refinancing that has taken place over the last few years) ”
I’m not sure refinancing would really be a good test of title insurance. It’s only for the lender and presumably the borrower would know what had occurred since they bought (although pretend perhaps they forgot).
As to Iowa, I’ve heard of states that don’t use title insurance. I believe our Supreme Court has commented on the fees title insurance companies charge being outragious given the coverage, but I’m not sure what a better alternative would be (what Iowa does). Doing title manually is nuts (I saw an attorney do it once for a court case), and if there’s a mistake the liability falls on whoever did it.
Tim–what does Iowa do?
two more cents to add. 😉
“To me it’s no different than when the broker has the agents who work with call and ask for donations or to sponsor golf tourneys…only to not allow the same access to agents as their ABA. No thanks. I have better uses for my money.” YES YES YES I AGREE!!!!!
Funny that while many our competitors went out of business last year, we made it through though we hardly ever call on offices. We let the consumer facing marketing do the job of sales – that combined with quality of service which brings the word of mouth business.
Jillayne:
As usual, a great article. Really, it’s too much to comment on.
Title companies do not woo lenders and LO’s as ardently as they do REs, since the revenue for a purchase transaction is at least double or triple that of a refinance (insuring title from the seller to the buyer, then to the buyer’s lender, and usually an escrow in there as well).
Lenders/LO’s do NOT get to pick title companies on purchases, but they do on refis.
Is title insurance really insurance? How often are claims paid out? Isn’t there a law that says you have to pay claims to call it insurance?
It seems to me that title insurance is really 3 things.
1. A title search and a report to identify all liens on title to the satisfaction of the lender.
2. An insurance policy if something goes wrong with title.
3. An escrow service.
Items 1 and 2 are lumped together, while item 3 (escrow) most often follows selection of title, for convenience for either the seller, the buyer or the lender, in some combination.
I think the insurance portion is overpriced (do we REALLY need to double insure every transaction?), but the other services are probably priced about right.
Also, I saw mention in Kenneth Harney’s Sunday article that the HUD reform was going after the ABA’s
http://seattletimes.nwsource.com/html/realestate/2004298051_harney23.html
Among the key changes you can expect if the proposal is adopted after HUD’s 60-day public-comment period:
“Strictures on incentive packages marketed by builders and others that effectively pressure consumers to use affiliated companies but don’t deliver true economic benefits or discounts. For example, if a builder incorporates incentives into the selling prices of homes but requires use of affiliated mortgage, title or settlement agencies to obtain those extras, the builder would violate the rules.
On the other hand, incentives and discounts that are real — buying a package of mortgage, title and other services that costs much less than they would if bought individually — still would be allowed.”
Frankly, after reading the document, I do not think the Feds are serious about this subject, there is already WAAAY too much on their plates now.
Finally, the laws mean NOTHING without the funds and the intent to investigate and enforce them. The current administration is so firmly wrapped in the cloak of “free market
Jillayne:
As usual, a great article. Really, it’s too much to comment on.
Title companies do not woo lenders and LO’s as ardently as they do REs, since the revenue for a purchase transaction is at least double or triple that of a refinance (insuring title from the seller to the buyer, then to the buyer’s lender, and usually an escrow in there as well).
Lenders/LO’s do NOT get to pick title companies on purchases, but they do on refis.
Is title insurance really insurance? How often are claims paid out? Isn’t there a law that says you have to pay claims to call it insurance?
It seems to me that title insurance is really 3 things.
1. A title search and a report to identify all liens on title to the satisfaction of the lender.
2. An insurance policy if something goes wrong with title.
3. An escrow service.
Items 1 and 2 are lumped together, while item 3 (escrow) most often follows selection of title, for convenience for either the seller, the buyer or the lender, in some combination.
I think the insurance portion is overpriced (do we REALLY need to double insure every transaction?), but the other services are probably priced about right.
Also, I saw mention in Kenneth Harney’s Sunday article that the HUD reform was going after the ABA’s
http://seattletimes.nwsource.com/html/realestate/2004298051_harney23.html
Among the key changes you can expect if the proposal is adopted after HUD’s 60-day public-comment period:
“Strictures on incentive packages marketed by builders and others that effectively pressure consumers to use affiliated companies but don’t deliver true economic benefits or discounts. For example, if a builder incorporates incentives into the selling prices of homes but requires use of affiliated mortgage, title or settlement agencies to obtain those extras, the builder would violate the rules.
On the other hand, incentives and discounts that are real — buying a package of mortgage, title and other services that costs much less than they would if bought individually — still would be allowed.”
Frankly, after reading the document, I do not think the Feds are serious about this subject, there is already WAAAY too much on their plates now.
Finally, the laws mean NOTHING without the funds and the intent to investigate and enforce them. The current administration is so firmly wrapped in the cloak of “free market
Marketshare for Commonwealth in 2001 was 2.59%. In October 2007: 14.58%. This has been accomplished by ownership/brokers blocking out all competing (non ABA) reps except for their new lower paid unknowns and Transnation reps that wore both hats.
This is big time money for brokers and like shooting fish in a barrel.
J, thanks for your very informed, very informative title info. I’m going to forward it to our manager — who, incidentally, has never strong-armed us to use our affiliated services.
I feel strongly about this because the Windermere offices in south King County were my top accounts. If I were still in the biz, the business practices of the top brokers (not just Windermere) would be crushing to competing non-ABA title companies. I’m glad I’m out of that industry.
As a mortgage professional, I can and do go directly to consumers. A title rep cannot. The agent has the most control on where the title order goes and purchase title orders pay more than refis to a title rep.
Jillayne:
As usual, a great article.
Title companies do not woo lenders as ardently as they do Realtors, since the revenue for a sales transaction is double that of a refinance (insuring title from the seller to the buyer, then to the buyer’s lender, and usually an escrow in there as well).
Lenders/LO’s do NOT get to pick title companies on purchases, but they do on refis.
Is title insurance really insurance? How often are claims paid out?
It seems to me that title insurance is really 3 things.
1. A title search and a report to identify all liens on title to the satisfaction of the lender.
2. An insurance policy if something goes wrong with title.
3. An escrow service.
Items 1 and 2 are lumped together, while item 3 (escrow) most often follows selection of title, for convenience for either the seller, the buyer or the lender, in some combination.
I think the insurance is overpriced, and the services are probably priced about right.
Also, I saw mentino in Kenneth Harney’s Sunday article that the HUD reform was going after the ABA’s
http://seattletimes.nwsource.com/html/realestate/2004298051_harney23.html
Among the key changes you can expect if the proposal is adopted after HUD’s 60-day public-comment period:
“Strictures on incentive packages marketed by builders and others that effectively pressure consumers to use affiliated companies but don’t deliver true economic benefits or discounts. For example, if a builder incorporates incentives into the selling prices of homes but requires use of affiliated mortgage, title or settlement agencies to obtain those extras, the builder would violate the rules.
On the other hand, incentives and discounts that are real — buying a package of mortgage, title and other services that costs much less than they would if bought individually — still would be allowed.”
Jillayne:
As usual, a great article. Really, it’s too much to comment on.
Title companies do not woo lenders and LO’s as ardently as they do REs, since the revenue for a purchase transaction is at least double or triple that of a refinance (insuring title from the seller to the buyer, then to the buyer’s lender, and usually an escrow in there as well).
Lenders/LO’s do NOT get to pick title companies on purchases, but they do on refis.
Is title insurance really insurance? How often are claims paid out? Isn’t there a law that says you have to pay claims to call it insurance?
It seems to me that title insurance is really 3 things.
1. A title search and a report to identify all liens on title to the satisfaction of the lender.
2. An insurance policy if something goes wrong with title.
3. An escrow service.
Items 1 and 2 are lumped together, while item 3 (escrow) most often follows selection of title, for convenience for either the seller, the buyer or the lender, in some combination.
I think the insurance portion is overpriced (do we REALLY need to double insure every transaction?), but the other services are probably priced about right.
Also, I saw mention in Kenneth Harney’s Sunday article that the HUD reform was going after the ABA’s
http://seattletimes.nwsource.com/html/realestate/2004298051_harney23.html
Among the key changes you can expect if the proposal is adopted after HUD’s 60-day public-comment period:
“Strictures on incentive packages marketed by builders and others that effectively pressure consumers to use affiliated companies but don’t deliver true economic benefits or discounts. For example, if a builder incorporates incentives into the selling prices of homes but requires use of affiliated mortgage, title or settlement agencies to obtain those extras, the builder would violate the rules.
On the other hand, incentives and discounts that are real — buying a package of mortgage, title and other services that costs much less than they would if bought individually — still would be allowed.”
Frankly, after reading the document, I do not think the Feds are serious about this subject, there is already WAAAY too much on their plates now.
Finally, the laws mean NOTHING without the funds and the intent to investigate and enforce them. The current administration is so firmly wrapped in the cloak of “free market
You want to talk about an awkward situation?
Our office produces well into the six figures of title insurance revenue through referrals. Yes, escrow can direct business. Do the reps that call on our escrow office provide me with any service? Nope. But they sure as heck make a boat load of money off us. Major bank.
Do those reps actively compete with me for work? Yes. How awkward is that? Just nuts.
Tim, maybe you need your own ABA! 😉
Ask any title company who is not a part of an ABA what the response is when they call on a real estate company who has an ABA relationship with title company.
I’ve seen emails where the reps have contacted the broker of such companies (as Jillayane has named) offering to come in to speak for a few minutes to agents about new discounts, products, education…you name it. The responses from the brokers were all the same tone “thanks but no thanks…we have a financial relationship with ABA title company”.
How is that good for the consumer?
And this has paid off big for the brokers and owners…check out the market share I quoted on #50–Commonwealth’s piece of the pie has increased 5 fold from pre-ABA title days.
Jillayne,
“can be re-allocated towards hiring exceptionally high quality internal staff”.
Here, Here! What I’ve been complaining about for over 10 years. Our favorite title escrow closer informed us she’s leaving the business. Hours are too long, stress is very high….
You can’t tell me that the major title companies don’t have the money to do this.
Jillayne:
I’ve been trying to comment for two days.
It says duplicate detected, but I do not see the original.
Am I banned for excess verbosity? 🙂
Diane:
Good to see some title reps in here. Correct me if I’m wrong, but aren’t the rules, regulations, customs and pricing for title insurance, title services and escrow services radically different from state to state?
I don’t do much lending outside of WA, but when I have, I have been very surprised at the differences in title insurance and settlements services.
Good to see someone from the title end of things is blogging (and disseminating knowledge), instead of trolling offices in skin-tight designer outfits!
ROFL….good one, Roger.
Yes, it’s different all over and that does make the job of regulators AND bloggers tough. 😉
That aside there are many similarities and I think it’s safe to say that the giving of things of value in exchange for referrals is a problem everywhere as is the master/slave conflict inherent in the affiliated business model.
Roger,
Re your comment 58 Askimet pulled you into the spam filter, likely because it was a very long comment with a link. I fished out the earliest of the three as the other two appeared to be duplicates. When I fish it out it appears where it would have been, so see comment 50.
Email me if you have trouble in the future. Not eveyone has the editor function to go into the spam filter.
ABA’s are dangerous to the consumer and although currently legal, should be looked at closely. Anytime you have multiple interested parties in cahoots with each other the possibility of malfeasance increases. I blogged on this a while back with regards to appraisals; http://shaferfinancial.wordpress.com/2008/02/08/lawsuit-attacks-developerlender-cartel/
Until the real estate business buys into total transparency there will be regulatory problems and hard feelings from consumers!
A few years ago Texas did away from allowing title companies to subsidize or discount anything at all for us. For years, agents could get business cards, brochures, meals, head shots and all sorts of stuff from title reps. After P53 was passed and this ended, title insurance came down around 6%. So the winner in the end is the consumer and that doesn’t hurt my feelings at all.
Aubrey Cohen has a post about this up at Seattle PI’s blog….here’s an interesting comment from “RealtorLee”
The brokerage that I am associated with also has a financial interest in a title company (as well as a mortage company) with ‘one stop’ shopping representatives in our office. There is a lot of pressure from management to use their representatives, but ultimately they cannot dictate that we use them. Contrary to one the reprentatives quoted in the article,
our office (like most of our corporate owned offices) has a ‘closed door’ policy preventing competing title (and mortgage) sales representatives from blindly solicitating business on the premises. As seasoned agents we debate this issue with management frequently as we view it as restrictive to our ability to offer
our Clients the best product in the market. As a concession, we are allowed to meet with competing title representatives, etc. in the lobby or outer areas only by specific appointment. Management’s argument seems to be “why would any business, let a competing company actively market on their premises?”
Hi Jillayne,
I’m currently in escrow fo selling my home and my agent just asked me if I wanted to save over $400 by switching out Commonwealth Title for Northpointe(?) title. My question for you is, is it safe to do this when I’m signing the paperwork tomorrow (closing next week)? I don’t want to jeopardize my sale.
Thanks,
BCS
Hi BCS,
Check with your escrow company to be sure this will not delay your closing.
I have heard that Northpoint recently reduced their title insurance rates across the board, so yes, this could end up saving you money.
BCS,
It may not be advantageous to do that. Potentially foolish.
1) It is astonishing to me that your agent would suggest this at this 11th hour. It is one thing one week into your transaction, but quite another when you are ready to sign your paperwork tomorrow.
2) If you moved title and or escrow you may receive a Bill for services rendered by Commonwealth and they have every right to collect and should. Whether they do is up to them.
3) Presuming the buyers loan docs are also ready for signing, the buyers complete loan package was prepared with fees already accounted for and by moving title and escrow it is possible that the lender would have to re-draw documents with new title and escrow co. and any other fees that they may charge (actual and third party).
4) It would be easier to have Commonwealth just match the fees.
5) Negotiation and shopping for title and escrow should be completed the day you and the buyer came to agreement.
If it works out then you can’t argue with saving money, but if it doesn’t and a delay is created then you may have shot yourself in the foot.
Congrats on the sale.
Hi Tim,
CWealth can’t match the title fee, their rates are set by the insurance commissioner.
You make a good point in regards to the CWealth cancellation fee. This usually runs around 50 to 60 dollars plus tax.
I’m wondering if BCS’ agent didn’t suggest this because BCS might have been trying hard to save money/cut costs any way possible.
Yes, the TIME element is crucial. BCS, talk with your escrow closer!
Why would the insurance commissioner care if the fees were reduced?
I agree, Leanne. And if rates are “set” how can there be such a big price difference?
Hi Leanne,
Our insurance commissioner cares because title company rates are regulated. If a title company rates are too low, then a title insurance company many not have enough money set aside to cover claims.
Please no jokes about how low title insurance claims are 🙂 I’m just delivering the theory.
If a title insurance company wants to raise or lower their rates, they must file a rate schedule change with the OIC (Office of the Ins. Commissioner) and receive approval on that newly created rate, justifying either the increase OR the decrease.
Well, in real estate, nearly everything is negotiable, so maybe the title companies just decided to have a ‘sale’ …
I can understand an insurance commissioners office limiting fees on the top side, but why would they care if fees were lowered?
However, this late into your sale, for $400, I wouldn’t agree to take any risk if I were you.
Hi BCS,
Northpoint Escrow and Title recently filed a new rate schedule with the OIC to reduce their title insurance rates across the board. Let me see if I can find some collateral on this.
http://onenorthpoint.com/
Hmmm. Nothing on their site justifying the cut. I was told that they justified their rate cut because of cost efficiencies due to their computer information systems. Everything is electronic now at Northpointe, no more paper title reports.
Hi Leanne,
The OIC cares because it is their job to regulate the solvency of insurance companies. Rates that are too low are not good for the consumer if your insurance company goes out of business.
Look at it from the perspective of the subprime meltdown.
Lenders UNDERCHARGED the risks on subprime loans, Alt A loans, and prime ARMs and we have one hellacious mess on our hands.
Tim, you’re right about comment 70, point #3…the lender would have to redraw loan docs because of the new fees. BCS should check with the lender to make sure there is not a redraw fee and that this is do-able if they want to proceed.
Hi Jillayne, thanks.
BCS should also check to see if his loan lock is expiring soon, since changing might need an extension past his lock date.
And, the undercharging aspect seems fraudulent to me, no matter how you shake it. Entire groups of money managers simply couldn’t have been that stupid … but they certainly were. Astounding that things could be this messy.
Hi Everyone,
Thanks for your comments. I am going to talk to my agent a little bit more about what risks are involved with making that change. I don’t understand why it was suggested now and not back when she listed my house. I remember (although it was a few months ago!) her mentioning that the title company we were using was actually affiliated with her brokerage (Windermere).
Re Northpointe cost cuts.
They look real enough to me. They tout improved systems, which may be true, but the more likely explanation is they saw the future better than their competitors and decided to make a bid for increased market share in a down market.
Classic business strategy, sometimes wildly successful, sometimes disastrous.
As noted, they must file intended rates (annually?), and by law, cannot adjust those rates up or down, until the next filing.
As for switching at the last minute in a sale to save $200 bucks…not smart.
Jillayne, I seem to have several duplicate entries clogging up the post, do you mind removing them?
Thanks!
Roger, it was actually a little over $400 that I would save – not $200. So I called escrow and she said because it’s their own title department it would not put the transaction at risk and that I shouldn’t sweat the cancellation fee. Apparently those are rarely charged? Thanks again, everyone. Enjoy your weekend!
Hey, everyone, did you read BCS’ comment 82? WHOA. That’s pretty cut throat but I guess it must be that kind of market in title.
I’m looking at an addendum to a purchase and sale: Affiliated Business Arrangement Disclosure Statement. It states that
“through a subsidiary, it [the RE company] directly owns a minority interest in [a title and escrow company] and through common ownership, indirectly owns [interest in a mortgage company].
Because of these relationships, this referral may provide [the RE company] a financial or other benefit.”
Does not state it’s to the benefit of the buyer or they will receive a better rate for going thru the agent’s title/escrow/mortgage company.
Since this ABA relationship cannot benefit the agent in any way or it’s a kickback (if I’m understanding correctly); then do all the profits go to the broker?
Jillayne:
My posts 51, 55 and 56 seem to be duplicates.
I’ve been accused of not remembering what I say sometimes, and repeating an old story, but I hate to see it in writing! 🙂
Hi Rhonda,
It CAN benefit the agent….IF the agent owns a interest in the affiliated business.
Affiliated businesses (AfBAs) have many different forms of ownership.
Sometimes an owner of a real estate company owns 100% of the AfBA. Sometimes an owner is also the broker who owns 100%.
Sometimes a group of many agents pool their money to start the affiliated title, escrow, or mortgage company.
Sometimes it’s a group of broker/owners.
An AGENT who happens to work at one of those offices and does NOT own a business interest in the AfBA may not benefit in any way other than the “good service” provided by the AfBA. The profits go to the owners, whoever they are.
There is nothing in RESPA that says the AfBA must provide the lowest rates or fees for the consumer.
Jillayne, I’d leave Roger’s comments up so we can tease him later. 😉 Ya taught me something new about the ABAs. I’m still not for them as they squelch competition which is never good for the consumer.
Calling all state regulators and class action attorneys, here’s a slam dunk case. It appears to me that according to #3, that all Windermere, John L Scott and Coldwell Banker agents are dramatically overcharging their buyers and sellers by steering the title towards their own brokers title company. Correct me if I’m wrong, a title policy provides the same coverage no matter who issues it. How can these real estate owned title companies justify a fee that is hundreds and hundreds (per comment 82) more than the identital product issued from the same underwriter, Landamerica?
Jillayne, re 76–apparently Northpoint is not “green” (or at least, not enough to justify the lower rate)…they just increased their rates back up 30% (after just having them at the lower rate for one month).
Apparently just a “sales” blitz…it’s over now.
There is more to the Northpoint story than what meets the eye.
It will be interesting to hear what their side of it is. I’m surprised the State allowed the rates to change so quickly.
Rhonda:
Not sure what the “green” means, unless it’s the color of money.
Waiting to hear the rest of the story. The savings were real.