Kicked in the gut by a "flat fee" proposal, the already winded mortgage industry seems to be barely able to catch its breath from the CFPB's recent lurching toward yet another vaguely expected and somewhat ill-defined nostrum.
The pattern replays itself time and again: first the news, followed by the rulemaking proposal, which is then given a brief period for public acquiescence or remonstrance; and then inevitably the final rule, which is much like the initial proposal. Early on, industry associations issue a Call to Action!
Alas, when the Federal Register publishes the effective compliance date, everybody falls in line and scrambles to adjust. Sometimes, a few organizations even threaten litigation, though, when tried, litigating has not thus far brought about much satisfaction.
Exactly what is this Flat Fee debacle?
Let's take a peek at this flatland mystery.
IN THIS ARTICLE:
DAY OF RECKONING
YET ANOTHER COMMITTEE
OVERVIEW AND QUESTIONNAIRE
BEFORE AND AFTER
CREDITOR-PAID COMPENSATION - BEFORE AND AFTER
CONSUMER-PAID COMPENSATION - BEFORE AND AFTER
BROKERAGE-PAID COMPENSATION - BEFORE AND AFTER
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.