As the days wear on, we are learning more and more about HUD’s 2010 Good Faith Estimate. Yes, we’ve had the 2010 GFE to review for quite some time and HUD has offered several updates on their RESPA FAQs…however it seems to be taking a lot of practice, trial and error and communicating with fellow mortgage professionals and HUD to try to interpret what is intended and/or allowed with this new document.
HUD’s last revision to the FAQs made it loud and clear, in my opinion, that they want the Good Faith Estimate to be a tool for rate shopping… however unless the borrower has a bona fide property an address, this may not be possible. Why? As it currently stands, HUD will not allow later identification of a property address to create a “changed circumstance”. A “changed circumstance” (as defined by HUD) is required in order for a mortgage originator to be allowed to issue a revised Good Faith Estimate…otherwise, the mortgage originator is bound by that Good Faith Estimate until it expires (10 business days if the borrower does not express an intent to proceed with the application).
Per the most recent HUD RESPA FAQs from January 28, 2010 on page 17 regarding what qualifies for a changed circumstance:
Q&A 8ii: If a loan originator issues a GFE without identifying a property address, the subsequent identification of the property address, in and of itself, is not considered a changed circumstance.
If a mortgage originator issues a good faith estimate without a property address, they do so at considerable risk as the later identification of a property address does not constitute a changed circumstance. For example, a GFE was issued with the property address TBD and Block 8 = $0. The borrower later identifies a property and Block 8 should have been $2,000, but the originator cannot issue a revised GFE and is bound to the original GFE. Excise tax in most parts of King County is 1.78% of the sales price which would be a very bitter pill for a mortgage originator to swallow.
As a side note, it’s still hit and miss if lenders are disclosing seller paid excise tax on their Good Faith Estimates in Washington State. I’m hearing that some are making the mistake of not showing the owners title policy since it is also seller paid–this if flat out wrong–the owners title policy (even though it is paid by the seller) must be disclosed on the 2010 GFE.
I’m hoping for a revised FAQ soon (funny thing to hope for) where HUD may reconsider or clear this up. If they truly want home shoppers to be able to use the Good Faith Estimate to shop for a mortgage before they’ve signed a purchase and sales agreement…they need to provide us with more clarification…and soon!
The government couldn’t even design a simple one page GFE that actually makes sense and is practical for consumers, yet people want them to take over the entire health care industry?
The new GFE is a joke. Doesn’t aid in shopping and raises the cost of obtaining a mortgage. Secondly, why is the government encouraging rate shopping when that is nothing but a recipe for disaster in this type of lending environment? The last thing we need now are borrowers running around trying to save $50 bucks when it already is very difficult and time consuming to get a mortgage.
Russ… to shop after you’re in contract is terrible timing for a home buyer. Shouldn’t they select their mortgage originator before they get preapproved?
HUD needs to revise this on their next FAQ. If they truly want a borrower to have the full opportunity to shop, they need to start early. Changing the property address (or adding one) needs to be a qualified changed circumstance.
Borrowers should not be shopping for a mortgage after they are under contract, but they can’t get a formal GFE under the new rules until they actually have identified a particularly property which means they are most likely under contract.
Changing an address can have a significant impact on how a loan is priced. Especially if we are talking condos. All the HUD rules do is show that the bureaucrats making these rules have never originated or closed a single mortgage. No one with any real world experience would even dream up half this crap as they would understand how impractical it is to a real estate transaction.
Ultimately, the relationship between borrower and LO needs to fundamentally change. Borrowers needs to learn how to choose their lender earlier on in the process and rates should not be the primary driver of choosing an LO.
Russ hit the nail on the head! And this happens everywhere in all large businesses (which you might consider the government to be)……
Too many decisions are being made by people at the top that have NO real world experience. That’s the problem; simple as that. Government officials simply hear what the “problem” is and come up with their magical solution, which usually doesn’t correlate with the real world circumstances.
Of course, it’s not an easy fix and I don’t think there’s any good with simply complaining but I believe that’s the issue that needs to be addressed.
Great point Russ!
Josh Sanders
Founder, Shiloh Street
I’m hearing from my contact at HUD that if a borrower provides an address, which later changes, it could be considered a changed circumstance…
Now is probably a good time for me to remind LO’s that I nor my writings are a substitute for your compliance department…nor am I providing legal advice. Just sharing what ever I come across…having open discussions and hoping it helps!
Let’s pretend that we are only 25% below peak pricing for homes in Seattle and a Note is seasoned for 3 to 5 years.
A buyer would be dollars ahead by doing a blind escrow to amortize down a loan rather than get a new loan. If they had a down payment they could apply it to the principle balance.
The bank accelerate a Note? Come on!
The home owner in a partnership with a stranger for 5 to 7 years before a balloon payment? Foreclosure as an alternative? Risk is risk.
This fascination with new money, or should I say new debt, is bothering to me.
David, I’m wondering if your comment was intended for another post? It has nothing to do this topic–when we can and cannot issue a GFE. You might want to repost this where you thought it was going.
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This is exactly where the comment should be. No one should be looking for a loan. There is no need for a Good Faith Estimate.
We have come to an interesting market place where we will need to pay down principle balances in order to have equity.
Getting a loan is fifteen or thirty years of debt, no matter what the price of the money, the interest rate, or fees, it is just a debt to be paid. The quicker you pay the debt the more equity you build.
How long will this go on? The answer is in how long banks will control the Real Estate market place.
You’re right David. We should only pay cash for homes and never have control over our cash flow… Hey how about we don’t use RE agents either? At least if folks stop using mortgages, we’ve resolved any issues with the GFE.
Your comment still really has nothing to do with this post IMO. I’m not writing about whether someone should or should not get financing… I’m writing about the 2010 Good Faith Estimate.
You’re welcome to participate in the conversation we’re having about the 2010 Good Faith Estimate, HUD and borrowers trying to get preapproved.
before I click the link, care to give us a preview of what it’s about?
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You’ve been posting about paper work for loans that no one wants to do. No one wants to lend money for property so where is the incentive to make it easy?
We have had cycles in the 70s, 80s, and 90s, but nothing like what we have today.
We are in a market place that is extremely volitile. Any one in Congress, or the President, or Bernanke, even Volcker, can make some speach about Real Estate and the market place could tank over night.
I’ve read your articles and God bless, but we are in a position right now where some one would need to find a property, secure it, then apply for financing. The only certainty is that it’s a crap shoot.
As far as Real Estate agents go they need to be able to survive the next couple of years. Every deal they do today is going to come back and bite them.
David, people are still buying homes and obtaining financing… no, it’s not as easy as it was during the subprime era and I’m glad for that.
What do you mean your last sentence–that every deal a RE agent does is going to come back and bite them?
I can agree with David on where we’re at in “history” and the circumstances we face.
But what is the actual point you’re trying to make, David? Are you saying there’s no hope, we should all give up and therefore not need a GFE? 🙂
What’s the end result of what you’re trying to say?
Josh Sanders
Founder, Shiloh Street
There have been other times when the financing became secondary and people concentrated on paying down principle balances. There is a trend today that is advocating saving for a bigger down payment, but using amortization is a safer bet.
A loan is only the use of the money. So if I take over the payments on a $400K loan, put my down payment towards the principle balance, and make more than the monthly payment to further reduce the principle, both the buyer, and seller are coming out ahead.
You can make a contract for Real Estate. There are very few rules.
Rhonda and Russ:
Good points.
We did leave out the possibility that the new GFE was intentionally screwed up. It would be fairly easy for lobbyists to mislead government regulators with no real world experience.
Frankly, it’s hard for me to grasp that it could be done so badly without the intent.
Yet we go on with the business of lending.
And David, I don’t know what community or background you belong to, but the majority of people I know still need to borrow to eventually have ownership of a home.
I agree that folks need to reduce their debt load, and the national statistics seem to be pointing in that direction.
In the past year, I have had more people refinance and either bring cash in or reduce the term (or both) while substantially reducing their rate, than have taken cash out, or lengthened their term.
Roger, why would HUD have intentially screwed up the 2010 GFE? I can’t think of what their motivation would be.
I do think the big banks are pulling some strings at HUD to get them to rule that brokers needed to disclose the YSP. Unfortunately, I am not convinced that HUD actually even knows what YSP is so they just bow to the political pressure.
I am not convinced that there is a conspiracy of sorts, but the GFE is just an attempt to placate two parties. Namely big banks and consumer groups. Both of which have exponentially more clout than the broker community. Big banks want to disadvantage brokers and the consumer groups want to make it easier for borrowers to shop for loans.
The biggest issue is that the consumers groups have no freaking clue about residential finance, but they can hide behind sound bites like “predatory lending” etc. Unfortunately, the broker community made itself really easy to scapegoat and prove a “need” for this new GFE. Had we not had the housign bubble and so many foreclosures, I guarantee we woudl still be using the old form.
It is a half-hearted attempt to make it look like they are doing something to solve a problem that really didn’t exist.
I just thought of a reason why HUD may have intentionally created such a poor document–JOB SECURITY! They’ll be writing RESPA FAQs until the cows come home.
Rhonda,
If a mistake is made on the GFE, how is it rectified? Let’s say that you forgot to include the owner’s title insurance premium of $1000 when you issued the GFE. So now it gets down to closing and the loan officer has to “eat” that fee. Where does the money go? To the buyer who isn’t paying the fee? To the seller who is paying the fee? If you give a credit to the buyer at closing for a missed fee, doesn’t that mess up the ratios? Especially if it is an FHA loan and the buyer has to contribute a certain amount out of pocket.
Lynlee, that’s a great question–I’ve submitted it to HUD for their opinion. It’s a bit complicated…as soon as I have a response–I’ll let you know.
Rhonda, The new GFE’s are ridiculous and Shiloh is right — the top brass at HUD and other gov’t institutions don’t have real world experience.
Ihate to say it, but David Losh has a good point. Risky, but still valid. Here is how I see what he is saying, and I could be 110% incorrect — but let’s say we have a buyer who is buying a $400,000 house. He can either get a new loan for 80% of that, or he can go shopping for houses that have existing mortgages with a balance of something he finds appropriate to take over. No, he’s not going to formally assume this note, but he’s going to buy the house in all other legal ways. Seller has the risk that buyer might not make his mortgage payments at all or on time and wreck sellers credit — but seller might already have wrecked his own credit and not really care. Buyer has some cash to give to seller for a down payment, and that’s a beautiful thing to this seller.
So what buyer is looking for is a house with a loan product that he likes. Maybe instead of getting a new loan for 30 years at $320,000, buyer finds a seller with a mortgage balance of $350,000 and only 22 years left. Even if the interest rate is a little higher than it is today, we know that 8 years ago, rates weren’t all that bad. Buyer likes this loan, pays seller the $50,000 down payment, seller pays his real estate commissions, and closing costs, gets a smidge of cash (more than the bank was going to give him to just move out and not trash the place) and voila! Buyer now has a house with only 22 years to go. By making extra principal payments, buyer can take this note down pretty fast, more beneficial to him than the usual go-get-a-new-mortgage way.
We used to sell A LOT of houses when buyers could take title ‘subject to the note’. The ability fo quickly, and easily make a sales transaction work would go a long, long, long. looong way towards rebalancing this mess we’re in — and be a lot less expensive for me and you (taxpayers) and even the mortgage mess-makers.
Is this what you’re trying to say David?
I’m not an attorney, Leanne…but if a buyer took place in taking over mortgage payments (a wrap) of a non-assumble mortgage without the lenders consent, are they not a party to fraud?
The buyer and seller are both at risk in this circumstance…maybe I’m misunderstanding?
I’m sure there are Attorneys who would close a Wrap, but they usually end up being the case studies we read about in LPO clock hour courses. I’m uncertain how or if they’d be insurable transactions since we are not in a market where this is done much.
I don’t know either, but bet in a year we’ll start talking deeper about this.
I don’t know Rhonda if they would be committing fraud or not, that’s an attorney question. I know that I’d like loans to be wrappable like we used to do, and the ‘subject to the note’ FHA sales we did in the ’80’s made tons of houses sell instead of sit.
Moving properties is key, and if sellers could make their choice between certain foreclosure, or certain short sale, vs. selling to a buyer who wants to pay their mortgage – maybe lenders would see fewer defaults. I think we all are in agreement that something needs to change.
I keep wondering why the second position lenders don’t start negotiating with homeowners with a first mortage that isn’t too steep. Ie: if the second pays the 1st for something like a year or two — adds their help to the back of their note, reduces their note too, perhaps they end up with some sort of net instead of just total losses on those seconds … sure, they are taking on more risk, but long term, it could be set up to be a wash, or perhaps even a win.
If you read the deed of trust, it specifically states what the borrower/home owner can and cannot do. If the home owner/borrower is now trying to create a wrap, most DOT’s say they must be notified. Here’s an example from a Freddie Mac Deed of Trust:
“”If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender’s prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower.”
Leanne, if you are putting together contracts to sell homes and recommending a wrap or some other creative financicng that may constitute fraud in the underlying lender’s eyes–shouldn’t you be clear IF it is fraud or not?
Rhonda, I’m not going to put together contracts to sell homes or recommend wraps until the attorneys tell us it’s time. What I’m saying is that we could do this, legally, for decades and it was a normal part of transferring properties. I’m saying that we need to consider just about everything that has worked in the past, and consider why it worked. Movement makes economy.
For those who want to commit fraud, that’s up to them. They can decide to have an attorney advise them, and decide if the risk is something they’s take. I’m not going there — but I’m certainly willing to discuss the benefits of making some changes, that bring us back into a working economy.
Escrow companies? Which ones of them would put their license on the line? I’m sure there are some, but not many.
Kary will probably pop in soon to tell us that repealing the Garn act would help. I’m sure it would.
Thank you, and yes we used to do a lot of these.
The other point I was making is that no one wants to make Real Estate loans right now. It should be obvious that home prices are still over inflated.
Even if we take Ardell’s back pedaling of her “bottom” call scenario it will be 5 to 7 years before we see the real estate market stabilize. That’s a long time for the market to bump along.
It would be best to figure out how to circumvent the mortgage process in the mean time. We need the equity. More to the point is that Real Estate agents will need different tools.
David, I don’t know why you keep saying no one wants to make loans. I’m still originating and closing mortgage loans every day and I know I’m not the only LO out there who is successfully doing this.
No one wants to do a “no-doc” or “stated loan” is correct.
No one wants to do a loan without having an appraisal is correct (some may quailfy w/HARP-HAMP)
Your statement is not correct.
Hi All,
Trying to circumvent law has consequences.
Most note and deed of trust combos have a demand feature meaning if the seller conveys his /her title interest to another party, the lender may decide to call the note due.
This idea that nobody can get financing right now is not grounded in reality.
Folks having trouble qualifying for a mortgage loan are folks with bad credit scores who should stay renters for awhile anyways.
Leanne why would we want to advocate that a buyer buy a home without being able to gain title interest via a warranty deed? If someone has 50 grand for a downpayment they probably have the credit score and job needed to qualify for an traditional mortgage.
Rent to own scenarios do exist, but with values nowhere near stable (IMHO) people are better off just RENTING if they can’t 1) save the money for a downpayment and/or 2) cannot qualify for a traditional mortgage.
I have personally helped consumers who tried to do what you and David are referring to and it was a legal nightmare for the buyers. I helped them when things went wrong and they ended up coming to me to refinance out of that mess.
If someone wants a 22 year amortization, I’m sure a broker can find a lender out there to make that loan.
Wrap-arounds, without telling the initial lender, would not be something that I could ever advocate for any of my real estate agent students as mortgage fraud is now considered a class B felony in WA State.
Oh sure, “it doesn’t sound like fraud.” But then that’s always what people say when the FBI shows up.
Readers, if you’d like to assume an existing mortgage, you CAN do so by working through the existing mortgage company. You will fill out a loan application and your loan will be “processed” through the mortgage company’s loan servicing department. Now all parties to the transaction have been notified of the change of ownership interest.
For LEGAL advice on the best way to assume a person’s mortgage, please seek out your own favorite real estate attorney.
Jillayne, I wasn’t advocating anything. I was stating what we used to do, and how well it turned houses, which helped the cycle. Without a turn, we see decline.
Russ,
I have agree with you, however, part of the problem IS the loan originator and not the form.
No matter what version is used, if LOs are not filling out the form the way it was intended, lowballing, doing bait-and-switch, and committing outright fraud using the form, then the government definitely will swoop in and clamp down. Holding LOs accountable by falling off the other side of the horse is unfortunate.
This was HUD’s attempt to do something, I agree and I also agree that there were political motives.
However, the industry did this to itself by making trillions of dollars by using the GFE to deceive.
The industry gets what it deserves with this form.
The next step is for the Federal Reserve rule to pass that will dis-allow any LO compensation based on a higher rate. Goodbye YSP and goodbye SRP or overages for all LOs.
HUD already stated some interesting intentions with its latest proposed rule.
Jillayne, there are a lot of decisions being made by our government without having the full story, in my opinion. YSP and SRP are not always used as overages.
When YSP and SRP are gone, this means no more mortgages priced with zero points or zero costs…everything is par.
Hey Consumers–that’s our Government looking out for you…making rules with unintended concequences without having a real clue of how it’s going to impact the few of us who are remaining…and more important, the consumer.
Rhonda, 100% with you on this one.
Unintended consequences – every transaction seems to have surprises. So far, they’ve been quirky, irritating and/or extremely lame surprises — but we worked them out. I still don’t expect a closing to happen at all — till it finally happens.
For the millions of people looking at the internet for real estate advice, you should get an attorney. I am not an attorney.
What I talk about is the secret under belly of Real Estate.
David, your secret under belly could get a lot of folks in trouble.
Real Estate, property, is a transaction between individuals. Yes, lenders are overly involved because there is no chance for cash transactions. You can blame the bank, or the consumer, but the fact is housing units have to, let me repeat, have to come down in pricing.
There has been no other market that has been so far removed from affordability. I mean the type of affordability where the home owner has a reasonable chance of paying off the mortgage.
The trouble is the lenders. Lenders knew the value of the assets and made loans far in excess. Now it’s up to the consumer to correct the mess. Lenders are doing nothing but raking in massive profits and foreclosing on properties.
There is going to be a point where the laws will need to be changed so we can get some equilibrium.
Here’s another thing that has baffled me these past three years. You know about wraps, but we don’t discuss them. There are a lot of things that are never discussed in the web 2.0 world. Is that the transparency?
The consumer will need options. Pretending that the mortgage machine will keep churning is naive. In a few months even fewer lenders will want to dump money into mortgages. There are other things to do.
People are already in a lot of trouble.
There’s a secret underbelly? Ewwwwww.
Yes, Leanne there is an under belly of swapping Notes, negotiating with the banks, wrap arounds, and Real Estate Contracts.
Now let’s throw in all the foreclosures that may or may not be strategic. The guy up the street from me borrowed the absolute maximum he could then defaulted because he had a leaking oil tank. The bank did the repair, but still, it’s a mess.
How about all the people who purchased this year on a declining property value? Will the market be coming back any time soon? What is the incentive for lenders to allow Real Estate prices to decline?
It’s going to be up to the consumer, and Real Estate professionals, to figure this one out. Banks, or the government, are trying to protect what I now call a dead industry.
The discussion on the web2.0 centers around the paper work, or who can best fill out the paper work. In my opinion we should be moving along down the road from there.
David, yes, there is a lot of note swapping, wraps, and etc. Typical seller DOT’s or REC’s contracts aren’t fraudulent, or even a negative thing if the equity is there. Much of this is not for the average consumer, because of so many levels of risks, and potential fraud.
Is it fraud if a bank refuses or doesn’t bother to take action? Sure, but measuring risk has it’s own risks and rewards. I’m not advocating ‘for’ back door work, so much as being ‘for’ better solutions. We’ve got so many handicaps from doing our jobs, that we need to lessen the burdens, not increase them. Not only do we need some common sense approaches, but we need legislative action with research and intelligence behind it, not knee jerk ‘this will make me look good and get me elected’ kinds of things. The GFE form itself is the problem, not the desire for disclosure. Not allowing a note to be modified with standard rules, but creating expensive government offices (HOPE etc) to try to prevent foreclosures but not require lenders to adhere to certain standards, is a complete waste of tax dollars. Loan modifications with no required disclosures, in writing, to the consumer who is desperate to know what he might be agreeing too – who in their right mind thinks lack of disclosure is ever appropriate? Sellers unable to transfer their mortgage to a buyer of their choice — it worked for decades and decades, but as changes have occured, and more and more rules and regs piled on, and more and more risk taken by those who lend and manage the monies — something fell apart, and it’s all related. Simplifying it and calling it ‘fair play’ seems simplistic, but that’s really what it is. Those who have the gold make the rules, and this time, they didn’t play fair.
Of course I agree that a better solution is a front door solution, not back door solutions. But, as we move forward, it’s not completely out of line to think individual states won’t pass legislation to make underlying loans wrappable or transferable without lender approval. As one state moves in that direction, others will, we’ve become a nation of copycats, not leaders. I hope that it happens, because I think it will help.
Wow, Leanne: “Is it fraud if a bank refuses or doesn’t bother to take action? Sure, but measuring risk has it’s own risks and rewards.”
Well sure Rhonda, it’s why criminals take risks. They measure risk and reward. I’m not saying that’s what I think sellers or buyers should do. As agents we often meet prospective sellers who have sold their home to a friend who “assumed” their mortgage, without a formal approval. It’s not rare – and those people have no idea that they may have committed fraud. But the banks certainly take their payment checks quite willingly – so tell me this – if you were the bank, woud you rather have the money coming in, vs. spending money to go reclaim that property?
Let’s get off the fraud aspect of this discussion. The Garn act made due on sale clauses enforceable in 1976, I think. I’m not that old that I was selling homes then, but I can tell you all, that until some time in the 1980’s (maybe about 1987?), we could sell a home with an FHA loan on it “subject to the note” legally. And we did — we sold lots and lots and lots of homes and condos that way. Keep in mind that during the early 1980’s, interest rates were as high as 18%.
When you have a “no-qual” assumable loan at say 12% on your home, and the market interest rates are 14 or 15%, you have a pretty good chance of selling your home faster than the identical home next door that had a conventional loan (after the Garn act was passed).
Today we don’t have the huge fluctuations in interest rates – but we’ve got an oversupply of homes “underwater”. If a buyer could buy a home “subject to the note” without qualifying to the bank, there would be more transfers of sale. More excise tax earned too — which as we well know, funds a great many programs for communities. More people employed etc etc etc. Sure, less money for lenders on new transactions — but at the same time, creating stability will create more balance. Interest rates have been very stable for many years, there are huge numbers of mortgages at great interest rates that if a seller could sell “subject to the note”, foreclosures would lessen.
The statistical claim is that 50% of loan modifications fail. Well then, why aren’t we willing to take a trial run with “subject to the note” assumptions and see if 50% of them actually fail, or if a higher number stay current?
Your comment is a welcome surprise. There is nothing for me to add other than to thank you for making the argument so concise.
Thank you, David.
Lynlee, what is the percentage of LO’s who are showing excise tax on the GFE?
Rhonda,
We rarely see the GFEs. They typically aren’t sent to escrow and I haven’t seen one on a purchase transaction yet.
Wow… it would show on page 3 of the HUD, under fees that cannot change, if the LO disclosed excise.
Rhonda, I checked the HUDs on the purchases closed this year. None of them show excise tax on page 3. Don’t know if that is correct or not, but the funders are all accepting our HUDs.
that’s lynlee above. sometimes we use the same PC and she forgot to change her name. ;>
What was HUDs logic in making the lender responsible for transfer taxes? We have numerous ones here in Chicago depending on the county and it is very difficult to keep up with all of them. God forbid if you actually lend out of state too. There is no easy way to know all of the little things that change from place to place.
Seems a little detached from reality.
Russ, I think it boils down to HUD reacting the few bad apples who did the most damage as loan originators–low balling certain fees. But when would a LO ever quote excise or the owners title policy (at least in WA state, it is paid for by the seller).
I would not want to lend out of state right now! My preferred title company (The Talon Group) guarantees their title/escrow fees if you use their rate calculator and they provide the excise tax amount due. Our rates can vary from county to county.
This is kind of what started the whole debate and this post. I had a local LO contact me since they thought I was wrong about issuing a GFE w/out an address. Silly me, I thought it would constitute a changed circumstance when a borrower goes from “preapproved” and shopping for a home to having a bona fide offer… yet HUD spells out that if a LO issues a GFE w/out an address…it don’t fly…they cannot modify the fees that the new address would justify in changing.
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