Charlene,

In our Landtech seminars we ask if anyone knows of any industry in which there are no itemization of charges.

I really can't think of any.

Suppose you went to a restuarant and the waiter/waitress hands you the bill with only a line item, "Food and Drinks" with a total!! And should you ask for an itemization you're told that a government agency decided you would have a clearer understanding of the charges if only the "total" were provided.

Imagine going to Best Buy and getting several items with a line item "Electronics" and only a total. 

The question has been asked of HUD too many times to count -- "Please explain how this is clearer"!?!

The major point to remember with HUD's approach is the empirical evidence for the new GFE/HUD was only done with regards to the GFE. That is, the GFE was administered to loan applicants in testing to manufacture a document which allowed the potential borrower to pick the "lowest" cost loan. It is assumed by HUD that the "lowest" cost loan is the best for the borrower most often.

However, absolutely no testing was done with regard to the HUD and whether it is clearer and simpler. I have not heard one person from anywhere in this industry describe or even allude to the new GFE/HUD being a better document. In fact, as you comment, everyone I know is scratching their heads wondering who is so out-of-touch.

It appears to me a bunch of young Ivy League economists got together within HUD and came up with this "total" idea which they believe will change the world for the better. Too bad they hadn't sat at a settlement table for some years prior to their inspiration!!

I would also have HUD point you to any part of the Regulation which prevents "adminstrative and service fees" from being detailed.

We see many providing an "addendum" report which has this detail.

It would be interesting to see HUD prevail in enforcing such a matter. I think any impartial person would laugh at HUD  "trying to hide, mask, bury, camouflage, cloak, cover, disguise, duck, veil, withhold ,suppress or obsure"!!

In fact, this may be an action on behalf of all borrowers against HUD that they are being denied the full and detailed accounting to which they are entitled!!

Wyatt

You are so right.  I would never accept a bill from any establishment that did not itemize my purchases whether they were food or electronics.  What a great analogy!!

I am just so dang tired of this idiocy "on behalf of consumers". We in the industry sitting at the closing table know what the consumer wants and the new HUD is not what they want.  But alas, it seems we are stuck with it.  As for me I will gladly give an itemization is one is requested.

It won't be long I bet before someone gets a clue and in fact does see that this failure to disclose is a violation of basic consumer rights. 

Thank you for reading my rants and ravings!!

The closing packages which I prepare, of course, only totals the title services fees.  However, all of the attorneys for whom I search titles and prepare their closing packages have been print the itemization of Title Services, etc.  Due to the fact that my abstract fees are separate from what the closing attorney charges, these attorneys want the borrowers to know that he/she is not receiving the total as shown on the HUD.

Yes, I agree that HUD is fooling itself.  I, too, consider the new HUD-1's to be in direct violation of RESPA.  In fact, while attending a title underwriter's seminar, the Vice President of the title company stated that he felt there would be litigation in this regard.

Donna

This huge government agency whose job is to protect and defend the consumer has absolutely no idea what goes on at a closing table. I would not be at all surprised if some day soon there is a class action suit filed against either an individual title agent or his/her underwriter for failure to properly disclose.

I feel it is important to the consumer that an itemization be given prior to the consummation of their transaction so that they can in fact make an informed decision relating to the fees that they are being charged and to whom those sums of money are going to be disbursed.  Additionally, as you said Donna, we don't want the consumer to think that our "lump sum" is all being paid to us, the lowely title agent :)  It is not fair to our industry that this misrepresentation of our fees is being mandated by HUD. 

Thank you for your input. I appreciate you reading my rants and ravings.