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Zillow and Reg Z Changes

Profile picture for John Paunan
Obviously, Reg Z changes are nearly upon us, and for some lenders they already are, and I assume everyone's reworking their business models to stay in compliance.  But I'm not seeing a whole lot of discussion or disclosure from the online rate engines, like Bankrate and Zillow.  Reg Z presents a fundamental change to how lenders do business and are able to quote their services. There is a lot of discussion of the impact on rates, but frankly, that's about the least important/drastic aspect of the regulatory change.  It's really about the impact the compensation model has on the fee disclosure, which as a byproduct alters the offered rate.  

Zillow should be creating another field for rebate and requiring all fees, whether covered by the rebate or not, be fully disclosed. Anything less is a violation of Reg Z. We're all aware of the abuses of the past, in particular on the ZMM, but that will all pale in comparison with what could ensue if this matter isn't properly addressed now.   
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March 30 2011 - US
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Answers (44)

Best Answer
"the smartest LO ever to grace the planet is the one that was smart enough not to get into this business."

Very True. Point taken.
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April 05 2011
Profile picture for Pasadenan
John -

Has anything gotten better since?  Any news of the eventual rebate field yet?
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April 13 2011
Profile picture for AgentMarketing1
i 2nd JP's "Best Answer" choice.. "the smartest LO ever to grace the planet is the one that was smart enough not to get into this business."

The party's over mi LO amigos'... we seen the Boom, the Bust & now the excessive & prohibitive regulation that's attendant to every Boom-Bust cycle.

Mortgage Lending's being homogenized... the chairs ar destined to be filled by hourly W-2 employees cranking out a 9-5 for wages or a salary...

me thinks them that's out be the lucky one's...


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April 07 2011
Profile picture for Krep34
"That one is definately laying in the pasture."

But nothing will happen because the people doping the "mystery shopping" have zero idea what they are doing. The arrogance they display by thinking they understand this better than the experts that do it daily is impressive. The public has no idea what to think because cow chip quotes like this are allowed with no consequences but to shoot the messenger. 

Post a quote request yourself... see the BS in living color!
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April 07 2011

That one is definately laying in the pasture.

There's not enough in the 4% or even 4.5% MBS to allow that price.

I do a lot of high-balance; I have yet to see anyone want to pay more than about a half point; it seems he's wasting bandwidth advertising 1.25 points anyhow.

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April 07 2011
Profile picture for Krep34
"examples?"
http://www.zillow.com/mortgage/BorrowerQuoteDetail.htm?quote=ZQ-YZCSRHD

Explanation for the layperson:
4.625% is quoted with 1.25 discount points on a 600K high balance loan.
4.625% could only be achieved on this through a borrow paid scenario paying only 1.25 points.
There is no origination fee disclosed on this quote so if it is borrower paid, it is not in compliance.
If this person is claiming that this is lender paid at 4.625% for a 600K loan at a cost of  1.25 points, they are a liar.

Conclusion: this quote is impossible.
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April 07 2011
examples?
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April 07 2011
Profile picture for Chris Corica

I have reviewed multiple quotes on various requests and can find quotes which are in violation of the new Reg Z changes on just about every single request. Are zillow quotes required to have any type of accuracy within the law or are they like zestimates and should simply be used for entertainment purposes? 

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April 07 2011
Profile picture for John Paunan
This quote needs to be mystery shopped!!
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April 07 2011
Profile picture for Jason Hall

At present, quoting on ZMM represents a greater liability than reasonable when expecting some business from the source.  If you end up being sued, losing your license or going to jail over quoting online and not being compliant, it's just not worth it.  I don't see how anyone could risk that as presently constituted.  Until they figure it out, it's best to wait on the sidelines I think.

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April 06 2011
Profile picture for John Paunan
I've tried emailing various staffers to discuss the law and compliance from a practitioner's perspective, but no one has followed up. Considering the amount of training we've had to go through with our lenders just to keep our business agreements in place, we should have a fairly firm grasp of the law's implications, though, the ZMM quotes I've seen seems to indicate otherwise.  

If Zillow wants to simply take the approach of here is a general rate/fee combo and defer to lender discretion, then that's one thing; but that's not how the ZMM is advertised, nor is it in-line with the intent that Zillow's employees have represented numerous times on the boards. Zillow is different because it's anonymous (no pressure) and it's accurate.  They go so far as to say they verify quotes through a Mystery Shopper program.  Well, as someone with a vested interest in the ZMM and staying competitive as a small broker, I just want them to back that up...   
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April 06 2011
Profile picture for Pasadenan
John -

I agree with you, but Kristin E-mailed me when I asked, stating they believe the quotes can presently be done legally without the rebate field, and that it will take them longer to get that field added...

I still don't see how it could be legal with the information you provided on how the percentages are rounded differently wholesale and retail...

I think you should E-mail Spencer on this issue.  Though I'm sure their legal council already looked at it, and they probably had a few loan officers look at it, it doesn't appear that most are understanding the issue.
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April 06 2011
Profile picture for John Paunan
Geoff,

So you do realize that the quotes made until then will technically be illegal, right? Also, will you guys be adding a rebate field as well?  I spoke with LoanSifter and they agree that a rebate/overage field should be included, which will provide a correct way of disclosing reduced/no closing cost quotes.  

Again, I have no problem competing with anyone in terms of rates and fee combinations, I just want to do it in a legal manner.  As currently structured, Zillow does not allow for that...
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April 06 2011
Profile picture for Geoffrey ONeil
John,

The fix is scheduled for next week. The view switching you are seeing is a result of testing different versions of the quote details page. The bug only causes problems on some of the pages.

-Geoff-
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April 06 2011
Profile picture for John Paunan
Now it's back to no fee details and no flag button: Non-compliant quotes!
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April 06 2011
Profile picture for Paul Mondello
This is not a drill!
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April 06 2011
Profile picture for John Paunan
Geoff,

Looks like the fee details is back, but there is still no flag button and it is desperately needed!!!  

A little tip, if a lender is quoting discount, but no lender or underwriting fee, then there's a problem because the discount implies a below par rate factoring in compensation. The lender cannot then pay for the lender/underwriting fee with their overage because there is none, and there is always a lender/underwriting fee...
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April 06 2011
Profile picture for Pasadenan
I just searched my cache for an earlier copy of this thread... can't find one;

SO, again, the reference to the earlier "hall of shame" discussion thread that I missed in my list????

Can the headless person post it again please?  (Zillow deleted it without regard to the useful content...)
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April 05 2011
"And you would hope he would post so that Zillow wouldn't delete his profile too!"

Pretty sure if he posted the word "THE" it would be deleted.



BOO!
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April 05 2011
Profile picture for Pasadenan
Oh well, Google didn't cache this thread recently enough to have the post that had that thread reference...

Here is the link to Goggle's cached copy of this thread:
Google Cached Copy of this thread

Goggle will probably keep the cached copy around for a month or two, but then they tend to replace the cached copy every time they craw the thread, so who knows?

But they did crawl it today!
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April 05 2011
Profile picture for Georgia Loans
LOL! There is a touch of genius though, I've seen it!

Geoff, since you are around, will Zillow give John a gold watch when he is the first to hit 200??? ( On his own too!)
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April 05 2011
Profile picture for Pasadenan
By the way, can someone repost the thread number of the early HOS thread that I missed, since I didn't copy it down and don't remember seeing it?

(If I had opened it when I read this thread earlier it would be in my browser cache and history, but I didn't...)
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April 05 2011
Profile picture for John Paunan
Thanks for the response Geoff...had to give the best answer to the headless response!
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April 05 2011
Profile picture for Pasadenan
And you would hope he would post so that Zillow wouldn't delete his profile too!

So much useful content; just vanishes!

Maybe if we hurry, Google will still have a cached copy?

But the helpful content really belongs on the website!
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April 05 2011
the smartest LO ever to grace the planet is the one that was smart enough not to get into this business.
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April 05 2011
Profile picture for Geoffrey ONeil
John,

As I stated in the other thread regarding fees, it is only the lender view that currently shows the fees bunched. This is a bug that we are working on fixing as soon as possible. 

With that fix will come the return of the tool buttons as well, including the flag buttons.

-Geoff-
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April 05 2011
Profile picture for John Paunan
bump...
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April 05 2011
Profile picture for Georgia Loans
Shortcut to Hall of Shame Threads

Click and Scroll down, Pasa has them listed for ease of search!

The smartest LO ever to grace the planet suggested the idea for the HOS.

Who is that, Cutler?
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April 05 2011
Profile picture for John Paunan
It also looks like the fees aren't specifically broken down (RESPA violation) for any quotes.  What is going on?!  All other sites at least break down the fees.  As it is now, there is zero chance that rate/fee combinations will match up between what lenders are quoting on the ZMM and what they disclose to borrowers.  That is a recipe for disaster!
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April 05 2011
Profile picture for Georgia Loans
John, maybe a Wall Of Shame Thread until the flag button works?
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April 05 2011

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