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  • Comment Detail

  • Date: N/A
    First Name: Patrick
    Last Name: Ervin
    Email: ervin@talmerbank.com
    Organization Type: other
    Organization: Talmer Bank

  • Comment

    Any changes to pricing or G fee need to become effective on the APPLICATION DATE, not the delivery date. It is much easier to implement and properly prices each applicant. Also, instead of the LLPA matrix that was introduced before and then pulled back, an across the board increase in G Fee (if needed) would be better at any level instead of punitive LLPA's for people with high FICO's and 80 LTV etc. The high LLPA's for these clients is very disruptive for the industry because rates will be advertised at the "no LLPA" rate and then the actual rate will be higher for credit worthy borrowers. The originally proposed LLPA schedule would have created and industry that would be perceived as "bait and switch" since most borrowers would not qualify for the advertised no LLPA rate.