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#2241022 - 08/13/20 07:30 PM New Adverse Market Fee for Refinances
rgillette Offline
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Regarding the new Fannie and Freddie pricing adjustment - typically changes to MI or LLPA's are tied to an application date or case number assignment and lenders can disclose the changes to new loans. In this case it seems quite abrupt and any loan closing after 8/31 being assessed the fee.

For lenders with locked pipelines where those loans will close in September and October, will the lenders absorb those fees (50bps) or will they be able to COC it and pass to those locked customer? It seems like the former to me.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2241026 - 08/13/20 07:42 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
JWills, CRCM Offline
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The Mitten State
And our thinking was any loans with settlement dates as of 9/1 would be assessed the fee, so in order to avoid the fee we would have to close the loan, go through any rescission period, then settle with FM.
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#2241027 - 08/13/20 07:43 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
JWills, CRCM Offline
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The Mitten State
And do this all prior to 9/1, which really shortens the window.
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#2241028 - 08/13/20 07:53 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
rlcarey Offline
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I think that everyone needs to contact their mortgage industry group and the ABA and have them start screaming from the rooftops over this idiot move by the FHFA. I highly doubt this is going to be considered a valid COC in order to pass this fee down to consumers already in the pipeline and mortgage lenders are going to lose millions of dollars.
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#2241053 - 08/14/20 01:39 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
rgillette Offline
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Thanks. That was my impression. Awful if they don't at least push it out to application dates.

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#2241058 - 08/14/20 02:38 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
rlcarey Offline
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Galveston, TX
If you are an MBA member, they have a free presentation on the TRID implications today at 2pm ET:

MBA Presentation
Last edited by rlcarey; 08/14/20 02:39 PM.
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#2241069 - 08/14/20 05:13 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
krucker Offline
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Seems like we can't redisclose on a locked refi. For loans not locked is the CIC that is allowing us to redisclose the rate lock? Or does this fall under a situation where the lender relied on specific information to complete the loan estimate and that information later becomes inaccurate or changes? Do we need to issue a slew of new LEs quickly or can we issue a new LE as customers lock?

Seeing lots of talk online of admin in DC criticizing this also. Lots of media are starting to pick up this change too. Hoping this gets quickly changed.

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#2241089 - 08/14/20 07:57 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
rlcarey Offline
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Galveston, TX
Yes - you are pretty much out of luck on locked loans. But on an unlocked loan, you should be adjusting your pricing accordingly to recoup the new LLPA either through the interest rate or discount points.
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#2241201 - 08/18/20 07:03 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
John Burnett Offline
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Cape Cod
Of course, the timing by the Enterprises could not be worse for people struggling with finances, either. The optics are terrible.
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#2241602 - 08/26/20 02:31 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
Truffle Royale Offline

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And just like that it's gone again.

Wondering what they're going to do about loans that locked including the adverse market fee.

Never a dull moment when the gubmint is involved.

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#2241944 - 09/02/20 06:02 PM Re: New Adverse Market Fee for Refinances [Re: rgillette]
John Burnett Offline
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Cape Cod
As a lender, you can always close a loan with a rate that's less than promised in the rate lock agreement and/or exclude a charge (points, for example) that was going to be assessed per the agreement.
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