When Part 41 went into effect, my Broker I LO for went and either partnered with or assisted his friend who is also the lawyer we have always used to close loans with in becomming a title company? Now the lawyer fees for closing are sometimes cut 1/2 and title review fees are put in their place, if by some wierd chance he doesnt do a client title, his fees are back to the 550.00 range.

We are not allowed to use any other title company now other than his friends or we wont get paid commission. It takes 8 steps, 8 people from time we order a title, to time it is final title! I have very strong reason to believe they have or are getting around the Predatory Lending Laws by somehow re-arranging what fees are what etc? Am I just paraniod? or is this the norm now here in NY with Part 41?