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Let’s Make a Change

Andy W. Harris
Dec 03, 2013

Over the last several years, I have been heavily involved with the new regulations our industry is facing and understanding the impact of these new regulations on consumers and our business channels. During this time, I have noticed that some of the information shared or ways in which proposed rules were interpreted have been inaccurate regarding implementation. This led many to assumptions and the fear-based communication we’ve seen. Now, I believe there have been favorable regulatory changes. I also believe that the right operation and informed originator can prosper in any origination channel chosen with proposed and final rules. Until recently, I believe and I want to still believe that special interests and lobbying have been unable to influence the Consumer Financial Protection Bureau (CFPB) when drafting final rules. My concern is that this may no longer be the case due to the fact they’ve opted to provide unequal treatment to the way wholesale originations are regulated opposed to other channels. Let’s be clear, the three percent cap on points and fees rule under the Qualified Mortgage (QM) was to prohibit excessive or predatory loan fees … period. This was not meant to include fees in which the borrower does not pay, primarily when it can also result in negatively impacting the consumer unintentionally. My hope is that the CFPB does not yet understand fully consumer rate sheets as it pertains to YSPs (yield spread premiums) and SRPs (service release premiums) and they have just not yet had enough information to make informed decisions for final implementation. Because I hold onto this hope, I have developed an informative Web site for all mortgage loan originators who see the importance of a competitive primary mortgage market and who participate in brokering for the benefit of their clients (from mortgage brokers to bankers, credit unions, depositories, etc.). I have great confidence in wholesale lending, and I believe in making sure the truth and facts are disclosed to the general public as well as our federal regulators and legislators. These real-life samples and factual data need to be shared and added to so that a fair and level playing field is established. Please visit and share any comments. I am asking us all to join together with no affiliations, special interests or agendas … and simply do what we know is right and fair for equal lending and consumer choice. We have the ability to create all channels and disclosures equally, benefiting our employer, the consumer. Please send your company or individual name and URL in support and you will be added to the “We Support Change” section of the site. I thank you in advance Andy W. Harris, CRMS is president and owner of Lake Oswego, Ore.-based Vantage Mortgage Group Inc. and 2010-2011 president of the Oregon Association of Mortgage Professionals. He may be reached by phone at (877) 496-0431 or e-mail [email protected] or visit
Dec 03, 2013