Steve,
HUD is a consumer-centric agency, and the HUD-1 is a consumer-centric document. In HUD's new way of thinking, the consumer doesn't want or need full disclosure after all. All those numbers just confuse them. The bottom line is all that matters.
I remember when HUD was seeking comment on the new RESPA/TILA rules. There was a lot of talk about more disclosure and encouraging the borrower to shop around for the best deal. I see neither of that in the final rule, I do find it odd, however, that HUD insists on disclosing the agent-underwriter premium split, but not the individual costs incurred by the agent that are now rolled into the premium.
For what it's worth, my company has always rolled the cost of the title search into the premium. And the premium is the same whether the search is conducted in-house or farmed out to an independent abstractor. We just lose bigger when a file carrying the added expense does not close.
to post a reply:
login - or -
register