CFPB's Flatland Fee

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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.

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IN THIS ARTICLE:

DAY OF RECKONING

FLATLAND FEE

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

BRIEF DISCUSSION

RECAPITULATION

LIBRARY

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