45 days, not 30 for settlements

Like I have mentioned before on this site, the new laws have made a 45 day settlement a requirement. Before 30 days was very doable, but with the HVCC and HERA, 45 days is the norm. With the HVCC, you order the appraisal thru an AMC, Appraisal Management Company, and they are taking anywhere from 5 to 15 business days, from the time they receive the order. I will not even get into all of the problems the AMC and HVCC are causing, besides there turnaround times. With HERA, the new truth-in-lending disclosure, the banks are disclosing their own TIL to the borrowers after they receive the file. Most banks are sending out their new TIL in 24-48 hrs after submission. They are give 3 days for the borrowers to review the TIL. Once the time has expired, they will notify you of when you collect the money for the appraisal and ordered. This is around 5 business days. When you combined for of these new requirements, 30 days is too risky for any borrower. Any broker or lender that offers you 30 days, might have to charge you later on in the process to extend your rate, or risk losing that specific rate, since some banks are no longering offering extensions on rate locks. This is a very conservative market, and no one should be taking gambles, especially when it comes to rates.

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