RESPA is a CLO allow a broker and facilitator to reward them for their support?

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I’m starting a new business. There is a site for mortgage originators and real estate agents use to help their borrowers through the process. This is a real learning process is a RESPA requirement to cover the 14 elements (see below) is required for a home loan made. BrokerVine is a computerized loan departure. Therefore, it is a provider of settlement services because we provide services around the creation of mortgages. Our fees will be paid by the borrower at closing. We provide leads for real estate brokers, people who have volunteered to replace them, to introduce the mortgage originators. The author and / or agent to the customer through our website to escort her home value and the products and prices and other things. The plan is to pay the mortgage originator a commission for the work, do it for the CLO. There is no payment for returning leads for real estate agents and no refund for work not done. They are not paid by the transaction. The fees of the mortgage principal is paid directly to his mortgage company and then divided by their collective agreement. It is clear that the mortgage originator is an employee of the Mortgage Corporation. My question is: because the primary mortgage loan and the broker (who will get new tracks) do constructive work for COL, he is authorized to RESPA, to pay a premium for a party to the use of our products and the work is required? The broker is a mortgage originator, it is not an exclusive agreement to be bound. It’s an idea, I want to structure it correctly, I am flexible and willing to do something bald.Forschung: § 8 (b) prohibits giving or accepting “a part, division or percentage of contributions paid or received for the provision of a settlement service property … except for services actually performed. “Under the regulations, determined that the HUD restrictions and a fee for” no or nominal services are performed. “24 CFR § 3500.14 (c) The 14 tasks. 1.Take information of the borrower and filling Antrag.2.Analyze income and debt to determine the maximum mortgage that the borrower können.3.Educate allow the borrower to purchase a home, they discuss the different types of loan products and demonstrate how closing costs and monthly payments would be under each information unterschiedlich.4.Collect financial products and other documents that are part of the process demand (tax returns, bank statements, etc.) .5. Initiate and reviewed the agenda and work Lagerstätten.6 introduction and requests for mortgages and other loans Überprüfungen.7.Initiate Gutachten.8.Initiate and order inspections and enforcement or Berichte.9.Provide technical details of the borrower (the accuracy of the location, good faith estimate, etc.) .10. Assist the borrower in understanding and clearing credit problem. 11.Maintain regular contact with the borrower, the broker and lender between application and closing to inform them of the status of the application can collect and report additional information such as legal gebraucht.12.Order Dokumenten.13 . ist.14.Participate Determine if the property in a flood zone in geschlossen.Nur loan agreement in case, here is a guide, the leader by BrokerVine: 1.The RE agent works referred to in least half of the 14 tasks in RESPA, especially gezeigt.2.RE agent led to one of the originators of mortgages that are more involved. RE agent gets 2 new tracks BrokerVine work. No cost involved ist. 3 sender pays for the mortgage Aussicht.4 BrokerVine The 14 tasks are RESPA mortgage originator by using the site BrokerVine bedeckt5. origination fees for loans BrokerVine a computerized payment at closing and will pay much the mortgage originator to be done to make this work on the loan on behalf of the COL to support settings mortgage broker erstatten.Der – This is to comply with RESPA, and build a business that really helps to get loans is structured effectively. The customer has the backing of mortgage broker. OCOL using the agent and the author shows the perspective of the mortgage solution is the best. Thanks for your help

2 Comments
  1. Reply
    Expert Realtor
    January 29, 2011 at 8:06 pm

    You seem to have forgotten something EXTREMELY important.

    Real Estate agents don’t originate loans…mortgage brokers and loan officers do.

    RESPA CANNOT, under the regulations of the banking industry, be “knocked off” to a third party. It is the responsibility of the bank or mortgage company originating the loan and that is who is held liable.

    You can package it anyway you like…but that is called a “kickback”, and it won’t fly with RESPA.

    The loan originator NOR the Realtor can pay you anything…this is a kickback.

    There is absolutely, 100% no market for your business. Everything you mentioned is AGAINST banking regulations to shove off to a third party and it won’t fly with the Privacy Act either.

    I sure hope you didn’t waste too much money on it.

    Your “system” is so full of legal holes, I would highly suggest that if you want to go into the brokerage business, you just do so.

  2. Reply
    Lauren F
    January 29, 2011 at 8:18 pm

    Usually it means the lender wants to see that you have enough money in the bank to take care of any repairs that would make the home uninhabitable. Typically this is used when HUD homes are in major disrepair. They want to make sure you can actually live in the home, and that you haven’t tapped out every last dime you have to buy the house.

    Sometimes they are held in an escrow account with your lender. Othertimes, they just want verification that you have a bank account with at least $ x amount of money in it. The $ x amount varies depending on the price of the house and cost of needed repairs.

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