THE COST TO CONSUMERS OF LENDER-PAID ZERO CLOSING COST LOANS

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1 THE COST TO CONSUMERS OF LENDER-PAID ZERO CLOSING COST LOANS Report to The American Land Title Association By Dr. Nelson R. Lipshutz Regulatory Research Corporation 24 Radcliff Road Waban, Massachusetts May 29, 2007

2 EXECUTIVE SUMMARY In a series of recent presentations, various consumer advocates have suggested that changing from the present system of direct consumer payment for closing costs (including the costs of title search, examination, and loss reimbursement) to a system in which all closing costs are paid by the lender would lead to a decrease in total consumer costs. The argument made is that lenders could use their considerable market power to drive down the prices charged by providers of closing services, and would pass these savings on to consumers. The present study examines whether this is the case. In fact, many loans are made today with lender-paid closing costs. We have examined the comparative prices charged by lenders for loans in which consumers pay the closing costs directly and those in which the lender pays the closing costs. Our study shows that lenders price their services in a way that does not pass any savings along to the consumer. To the contrary: Average consumers pay 4 to 5 times more in additional interest charges over the life of a 30-year loan than they save in initial closing costs. Average consumers pay 2 to 3 times more in additional interest charges over the life of a 15-year loan than they save in initial closing costs. The APR for an average lender-paid closing cost loan is 10 basis points higher than the APR for an average consumer-paid closing cost loan.

3 TABLE OF CONTENTS Page I. INTRODUCTION 1 II. DATABASE 2 III. ANALYTICAL METHOD 3 IV. RESULTS 3 APPENDIX A DETAILED CALCULATIONS 5 APPENDIX B REGRESSION MODELS 23 APPENDIX C UNDERLYING DATA 80

4 I. INTRODUCTION The concept of lender-pay (a system in which all closing costs are paid by the lender and covered by the interest rate) has recurred frequently in public discussions of closing costs and housing affordability. The first modern proposals occurred in the HUD-VA study of the title insurance industry in and the Department of Justice Study of title insurance pricing in More recently, lender-pay was suggested in the GAO report on title insurance 3. The argument underlying these proposals has always been the same. Lenders, because of the large volume of their purchases, could exercise market power to drive down the prices charged by closing service providers. This contention may or may not be true. Closing service providers are not highly profitable, and it is unclear whether there is any significant room in their pricing. But even if lenders could force down the price of closing services they purchased themselves, consumer benefits would follow from lender-pay only if lenders passed any savings along to the consumer. Lender-pay loans already are fairly common in the mortgage marketplace, and are generally termed zero closing cost loans. This fact provides a basis for investigating lender pricing behavior to determine the degree to which any such savings are being passed on to consumers now. The present paper presents the results of such an investigation. 1 The Real Estate Settlement Process and Its Costs, a Report to H.U.D.-V.A., H.U.D The Pricing and Marketing of Insurance, Department of Justice, TITLE INSURANCE - Actions Needed to Improve Oversight of the Title Industry and Better Protect Consumers, GAO, April

5 II. DATABASE The database utilized in this study was comparative rate information compiled by Bankrate.com, a standard source for current mortgage information. The data utilized included nominal interest rates and typical closing costs (including points, origination fees, title insurance, etc.) for $225,000 (i.e., 80% of the current average home price) loans of four types: year purchase loan with a 20% down payment year refinance of an existing loan year purchase loan with a 20% down payment year refinance of an existing loan We compiled data for 14 cities: 1. Albuquerque 2. Boston 3. Charlotte 4. Chicago 5. Denver 6. Houston 7. Kansas City (MO) 8. Lakeland (FL) 9. Los Angeles 10. Madison (WI) 11. Miami 12. New York 13. Portland (OR) 14. San Francisco 2

6 III. ANALYTICAL METHOD For each city and each loan type, we developed a linear regression model of the nominal interest rate as a function of the closing fee amount. As was to be expected, the nominal interest rate rose as the size of the closing fee declined. However, the interest rate rose much more than necessary to recover the closing fee. Using the regression model estimates, we compared interest payments with a lender-paid zero closing fee loan to interest payments with a consumer-paid closing cost loan with a total closing fee of $2000 (which is a typical value). We also developed a linear regression model of the APR as a function of the closing fee amount, and compared the APR s for the same two loans. IV. RESULTS Our results are summarized in Table 1. (The detailed calculations are summarized in Appendix A. The regression models are summarized in Appendix B. The raw data are presented in Appendix C.) For both 30-year and 15-year loans, and for both purchase and refinance, lenders making zero closing cost loans set their interest rates so high that they charge the consumer multiple times for the closing costs. The APR of the loan is increased by about 10 basis points by the lender-pay mechanism. Lenders are not passing along any savings to the consumer that the lender realizes by the exercise of market power to drive down closing service provider prices. Such savings, if they exist, are being kept by lenders, who charge consumers multiple times for the amount of the closing costs the consumer would pay if the consumer paid for them directly. The universal adoption of a lender-pay model would not reduce costs to consumers. Instead, it would increase consumer costs substantially. 3

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8 APPENDIX A DETAILS OF CALCULATIONS 5

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26 APPENDIX B REGRESSION MODELS 23

27 30-YEAR PURCHASE MORTGAGE ALBUQUERQUE 24

28 30-YEAR PURCHASE MORTGAGE BOSTON 25

29 30-YEAR PURCHASE MORTGAGE CHARLOTTE 26

30 30-YEAR PURCHASE MORTGAGE CHICAGO 27

31 30-YEAR PURCHASE MORTGAGE DENVER 28

32 30-YEAR PURCHASE MORTGAGE HOUSTON 29

33 30-YEAR PURCHASE MORTGAGE KANSAS CITY 30

34 30-YEAR PURCHASE MORTGAGE LAKELAND 31

35 30-YEAR PURCHASE MORTGAGE LOS ANGELES 32

36 30-YEAR PURCHASE MORTGAGE MADISON 33

37 30-YEAR PURCHASE MORTGAGE MIAMI 34

38 30-YEAR PURCHASE MORTGAGE NEW YORK 35

39 30-YEAR PURCHASE MORTGAGE PORTLAND (OR) 36

40 30-YEAR PURCHASE MORTGAGE SAN FRANCISCO 37

41 30-YEAR REFINANCE MORTGAGE ALBUQUERQUE 38

42 30-YEAR REFINANCE MORTGAGE BOSTON 39

43 30-YEAR REFINANCE MORTGAGE CHARLOTTE 40

44 30-YEAR REFINANCE MORTGAGE CHICAGO 41

45 30-YEAR REFINANCE MORTGAGE DENVER 42

46 30-YEAR REFINANCE MORTGAGE HOUSTON 43

47 30-YEAR REFINANCE MORTGAGE KANSAS CITY 44

48 30-YEAR REFINANCE MORTGAGE LAKELAND 45

49 30-YEAR REFINANCE MORTGAGE LOS ANGELES 46

50 30-YEAR REFINANCE MORTGAGE MADISON 47

51 30-YEAR REFINANCE MORTGAGE MIAMI 48

52 30-YEAR REFINANCE MORTGAGE NEW YORK 49

53 30-YEAR REFINANCE MORTGAGE PORTLAND (OR) 50

54 30-YEAR REFINANCE MORTGAGE SAN FRANCISCO 51

55 15-YEAR PURCHASE MORTGAGE ALBUQUERQUE 52

56 15-YEAR PURCHASE MORTGAGE BOSTON 53

57 15-YEAR PURCHASE MORTGAGE CHARLOTTE 54

58 15-YEAR PURCHASE MORTGAGE CHICAGO 55

59 15-YEAR PURCHASE MORTGAGE DENVER 56

60 15-YEAR PURCHASE MORTGAGE HOUSTON 57

61 15-YEAR PURCHASE MORTGAGE KANSAS CITY 58

62 15-YEAR PURCHASE MORTGAGE LAKELAND 59

63 15-YEAR PURCHASE MORTGAGE LOS ANGELES 60

64 15-YEAR PURCHASE MORTGAGE MADISON 61

65 15-YEAR PURCHASE MORTGAGE MIAMI 62

66 15-YEAR PURCHASE MORTGAGE NEW YORK 63

67 15-YEAR PURCHASE MORTGAGE PORTLAND (OR) 64

68 15-YEAR PURCHASE MORTGAGE SAN FRANCISCO 65

69 15-YEAR REFINANCE MORTGAGE ALBUQUERQUE 66

70 15-YEAR REFINANCE MORTGAGE BOSTON 67

71 15-YEAR REFINANCE MORTGAGE CHARLOTTE 68

72 15-YEAR REFINANCE MORTGAGE CHICAGO 69

73 15-YEAR REFINANCE MORTGAGE DENVER 70

74 15-YEAR REFINANCE MORTGAGE HOUSTON 71

75 15-YEAR REFINANCE MORTGAGE KANSAS CITY 72

76 15-YEAR REFINANCE MORTGAGE LAKELAND 73

77 15-YEAR REFINANCE MORTGAGE LOS ANGELES 74

78 15-YEAR REFINANCE MORTGAGE MADISON 75

79 15-YEAR REFINANCE MORTGAGE MIAMI 76

80 15-YEAR REFINANCE MORTGAGE NEW YORK 77

81 15-YEAR REFINANCE MORTGAGE PORTLAND (OR) 78

82 15-YEAR REFINANCE MORTGAGE SAN FRANCISCO 79

83 APPENDIX C UNDERLYING DATA 80

84 30-YEAR PURCHASE MORTGAGE ALBUQUERQUE LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com Amera Mortgage Corporation American Enterprise Bank of Florida American Lending Group Inc Amerisave Bank of Albuquerque Bank of America, N.A Caprock Lending Countrywide Home Loans Daylight Discount Mortgage ebank Mortgage E-LOAN EverBank First Community Bank Guaranteed Rate, Inc LoansAtWholesale Mortgage Capital Associates Mortgage Integrity National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans The Money Store Wells Fargo Bank Your Best Rate Financial

85 30-YEAR PURCHASE MORTGAGE BOSTON LENDER APR RATE FEES IN APR The Money Store AAXA VirtualBank Disco unt Mortgage AFI Watertown Financial Savings Bank Agency Windsor Mortgage Financial Corporation Mortgage Corporation AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Amstar Mortgage Corp Bank of America, N.A Belmont Savings Bank Century Bank Citizens Bank of MA Countrywide Home Loans Digital Credit Union East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First New England Mortgage Corp First Transcontinental Financial Group Corp Homeland Financial Mortgage Co(BR) HomeQuest Mortgage, Inc Madrate.com Massachusetts Discount Mortgage Middlesex Savings Bank Mortgage Capital Associates National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans Powder House Mortgage Co., Inc Priceline Mortgage Quicken Loans Rockland Trust Company Salem Five Cents Savings Bank Select Financial Mortgage Corp Source Funding Corp Sovereign Bank Star Mortgage TD Banknorth Massachusetts

86 30-YEAR PURCHASE MORTGAGE CHARLOTTE LENDER APR RATE FEES IN APR AAXA Discount Mortgage Abba First Mortgage Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida Amerisave Bank of America, N.A BB&T Carolina Equity Services, Inc Countrywide Home Loans Daylight Discount Mortgage East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First Charter Bk Guaranteed Rate, Inc Mortgage Capital Associates National Mortgage Alliance Olympic Mortgage Consultants, Inc Priceline Mortgage Quicken Loans VirtualBank Wachovia Bank

87 30-YEAR PURCHASE MORTGAGE CHICAGO LENDER APR RATE FEES IN APR AAXA Discount Mortgage Agency Mortgage Corporation AimLoan.com Allstar Home Mortgage, Inc Amerisave Bank of America, N.A BankFinancial Chase Bank Countrywide Home Loans Downey Savings & Loan Assoc., FA ebank Mortgage E-LOAN EverBank Fifth Third Bank First Savings Bank of Hegewisch Guaranteed Rate, Inc Harris National Association JC Financial, Inc LaSalle Bank Liberty Bank for Savings Madrate.com Marquette Bank MB Financial Bank, NA Mid America Bank Mortgage Capital Associates National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Sterling Home Mortgage The Money Store VirtualBank Washington Mutual Bank World Savings Bank

88 30-YEAR PURCHASE MORTGAGE DENVER LENDER APR RATE FEES IN APR AAXA Discount Mortgage Absolute Mortgage Company Agency The Money Mortgage Store Corporation AimLoan.com Washington Mutual Bank American Wells Fargo Interban Bank c Mortgage, LLC American World Savings Lending Bank Gr oup Inc Amerisave Your Best Rate Financial Amstar Mortgage Corp Bank of America, N.A Bank of the West Camelot Mortgage Group, Inc Castlewood Home Loans Chase Bank Countrywide Home Loans Custom Home Lending Daylight Discount Mortgage DNL Mortgage Authority, Inc Downey Savings & Loan Assoc., FA Eagle Lending Corporation East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First Transcontinental Financial Group Corp Guaranteed Rate, Inc Hart West Financial, Inc KeyBank Liberty Savings Bank LoansAtWholesale Madrate.com Mortgage Capital Associates Mortgage Integrity MortgageMint National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans

89 30-YEAR PURCHASE MORTGAGE HOUSTON LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Austin First Mortgage Bank of America, N.A Caprock Lending Chase Bank Compass Bank Earth Mortgage E-LOAN EverBank Franklin Bank, S.S.B Guaranteed Rate, Inc LoansAtWholesale Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Renaissance Mortgage VirtualBank Washington Mutual Bank Wells Fargo Bank World Savings Bank

90 30-YEAR PURCHASE MORTGAGE KANSAS CITY LENDER APR RATE FEES IN APR aasent mortgage corporation AAXA Discount Mortgage ABI Mortgage, Inc AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Amstar Mortgage Corp B&L Bank Bank Midwest Bank of America, N.A BankLiberty Capitol Federal Commerce Bank Countrywide Home Loans ebank Mortgage E-LOAN EverBank First Federal Bank First National Bank of St. Louis Guaranteed Rate, Inc Mortgage Capital Associates Mortgage Integrity National Bank of Kansas City National Mortgage Alliance North American Svgs Bk One Easy Fee Home Loans Premier Mortgage Funding, Inc Priceline Mortgage Quicken Loans Total Mortgage Services U.S. Bank UMB Bank Your Best Rate Financial

91 88

92 30-YEAR PURCHASE MORTGAGE LOS ANGELES LENDER APR RATE FEES IN APR AAXA Discount Mortgage Absolute Mortgage Company VirtualBank Action Resid ential Mortgage Washington Mutual Bank Agency Mortgage Corpora tion Wells Fargo Bank AimLoan.com Windsor Financial Mortgage Corporation American Enterprise Bank of Florida World Savings Bank American Interbanc M ortgage, LLC Your Best Rate Financial American Lending Group Inc Amerimac Plaza West Financial Amerisave Amstar Mortgage Corp Avant Lending Group, Inc Bank of America, N.A Capital Network Funding Citibank City National Bank Countrywide Home Loans Daylight Discount Mortgage Downey Savings & Loan Assoc., FA E-LOAN Epix Funding EverBank First Federal Bank of California First Transcontinental Financial Group Corp Guaranteed Rate, Inc IndyMac Bank Madrate.com Mortgage Capital Associates National Bank of Kansas City National Mortgage Alliance NationsChoice Mortgage One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Providers Financial, Inc Quicken Loans SecureLend.com The Money Store Union Bank of California, NA

93 30-YEAR PURCHASE MORTGAGE MADISON LENDER APR RATE FEES IN APR AimLoan.com Amerisave AnchorBank, FSB Associated Bank Bank of America, N.A Centurion Financial Group Chase Bank Countrywide Home Loans ebank Mortgage E-LOAN EverBank First Wholesale Mortgage of Wisconsin Guaranteed Rate, Inc Hartland Mortgage Centers, Inc Integrity Mortgage Group, LLC Madison Financial Madrate.com Mortgage Capital Associates National Mortgage Alliance Priceline Mortgage Quicken Loans The Money Store U.S. Bank Wisconsin Wholesale Mortgage

94 91

95 30-YEAR PURCHASE MORTGAGE NEW YORK LENDER APR RATE FEES IN APR Agency Mortgage Corporation American Enterprise Bank of Florida Astoria Federal S&LA Bank of America, N.A Citibank, NA Concord Mortgage Corp Countrywide Home Loans East West Mortgage Company, Inc E-LOAN EverBank First Trade Union Bank First Transcontinental Financial Group Corp Garden City Mortgage Greater Rochester Mortgage Corporation Home Financial Services Inc HSBC Bank USA, N.A Lake City Mortgage Madrate.com Mountain Mortgage Corp Municipal Credit Union National Bank of Kansas City National Mortgage Alliance North Fork Bank Priceline Mortgage Quicken Loans Sovereign Bank State Farm Bank The Money Store Total Group Trident Capital Funding Union State Bank VirtualBank Washington Mutual Bank

96 30-YEAR PURCHASE MORTGAGE PORTLAND (OR) LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Bank of America, N.A Countrywide Home Loans Double T Mortgage, Inc Downey Savings & Loan Assoc., FA East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank Guaranteed Rate, Inc Hart West Financial, Inc KeyBank Mortgage Capital Associates Mortgage Integrity National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Providers Financial, Inc Quicken Loans Sammamish Mortgage Stashin Mortgage Services, Inc The Money Store U.S. Bank Washington Mutual Bank Wells Fargo Bank

97 94

98 30-YEAR REFINANCE ALBUQUERQUE LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com Amera Mortgage Corporation American Enterprise Bank of Florida American Lending Group Inc Amerisave Bank of America, N.A Caprock Lending Catholic Home Loan Countrywide Home Loans Daylight Discount Mortgage ebank Mortgage E-LOAN EverBank LoansAtWholesale Mortgage Capital Associates Mortgage Integrity National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans The Money Store Your Best Rate Financial

99 30-YEAR REFINANCE BOSTON LENDER APR RATE FEES IN APR AAXA Discount Mortgage AFI Financial Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Amstar Mortgage Corp Bank of America, N.A Countrywide Home Loans East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First New England Mortgage Corp First Transcontinental Financial Group Corp HomeQuest Mortgage, Inc Massachusetts Discount Mortgage Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Source Funding Corp The Money Store VirtualBank Windsor Financial Mortgage Corporation

100 30-YEAR REFINANCE CHARLOTTE LENDER APR RATE FEES IN APR AAXA Discount Mortgage Abba First Mortgage Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida Amerisave Bank of America, N.A Carolina Equity Services, Inc Countrywide Home Loans Daylight Discount Mortgage East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank Mortgage Capital Associates National Mortgage Alliance Olympic Mortgage Consultants, Inc Priceline Mortgage Quicken Loans VirtualBank

101 30-YEAR REFINANCE CHICAGO LENDER APR RATE FEES IN APR AAXA Discount Mortgage ABI Mortgage, Inc Agency Mortgage Corporation AimLoan.com Allstar Home Mortgage, Inc Amerisave Bank of America, N.A Countrywide Home Loans ebank Mortgage E-LOAN EverBank First Savings Bank of Hegewisch JC Financial, Inc Madrate.com Marquette Bank MB Financial Bank, NA Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Sterling Home Mortgage The Money Store VirtualBank

102 30-YEAR REFINANCE DENVER LENDER APR RATE FEES IN APR AAXA Discount Mortgage Absolute Mortgage Company Agency Mortgage Corporation AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Amstar Mortgage Corp Bank of America, N.A Camelot Mortgage Group, Inc Castlewood Home Loans Countrywide Home Loans Custom Home Lending Daylight Discount Mortgage DNL Mortgage Authority, Inc Eagle Lending Corporation East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First Transcontinental Financial Group Corp Hart West Financial, Inc LoansAtWholesale Madrate.com Mortgage Capital Associates Mortgage Integrity MortgageMint National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans The Money Store Your Best Rate Financial

103 30-YEAR REFINANCE HOUSTON LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Austin First Mortgage Bank of America, N.A Caprock Lending Earth Mortgage E-LOAN EverBank LoansAtWholesale Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Renaissance Mortgage VirtualBank

104 30-YEAR REFINANCE KANSAS CITY LENDER APR RATE FEES IN APR aasent mortgage corporation AAXA Discount Mortgage ABI Mortgage, Inc AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Amstar Mortgage Corp Bank of America, N.A Capitol Federal Countrywide Home Loans ebank Mortgage E-LOAN EverBank First National Bank of St. Louis Mortgage Capital Associates Mortgage Integrity National Mortgage Alliance One Easy Fee Home Loans Premier Mortgage Funding, Inc Priceline Mortgage Quicken Loans Total Mortgage Services Your Best Rate Financial

105 102

106 30-YEAR REFINANCE LOS ANGELES LENDER APR RATE FEES IN APR AAXA Discount Mortgage Absolute Mortgage Company Action Residential Mortgage Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC American Lending Group Inc Amerimac Plaza West Financial Amerisave Amstar Mortgage Corp Avant Lending Group, Inc Bank of America, N.A Capital Network Funding Countrywide Home Loans Daylight Discount Mortgage E-LOAN Epix Funding EverBank First Transcontinental Financial Group Corp Madrate.com Mortgage Capital Associates National Mortgage Alliance NationsChoice Mortgage One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Providers Financial, Inc Quicken Loans SecureLend.com The Money Store VirtualBank Windsor Financial Mortgage Corporation Your Best Rate Financial

107 30-YEAR REFINANCE MADISON LENDER APR RATE FEES IN APR AimLoan.com Amerisave Bank of America, N.A Catholic Home Loan Centurion Financial Group Countrywide Home Loans ebank Mortgage E-LOAN EverBank First Wholesale Mortgage of Wisconsin Hartland Mortgage Centers, Inc Integrity Mortgage Group, LLC Madrate.com Mortgage Capital Associates Mortgage Group of Wisconsin, Inc National Mortgage Alliance Priceline Mortgage Quicken Loans The Money Store Wisconsin Wholesale Mortgage

108 YEAR REFINANCE MIAMI LENDER APR RATE FEES IN APR aasent mortgage corporation AAXA Discount Mortgage ABI Mortgage, Inc AimLoan.com American Interbanc Mortgage, LLC Amerisave Bank of America, N.A Capital Mortgage Systems, Inc Century Financial Countrywide Home Loans Daylight Discount Mortgage Earth Mortgage ebank Mortgage E-LOAN EverBank First Transcontinental Financial Group Corp LoansAtWholesale Magnolia Mortgage Corp Main Street Financial Mortgage Marimark Mortgage, LLC Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Praneta Financial, Inc Priceline Mortgage PRIMEQ MORTGAGE Providers Financial, Inc Quicken Loans Shoreline Mortgage Corp The Money Store Third Federal Savings & Loan Treinor Mortgage Company Trident Capital Funding United Mutual Funding Corp VirtualBank West Coast Financial Windsor Financial Mortgage Corporation Your Best Rate Financial

109 30-YEAR REFINANCE NEW YORK LENDER APR RATE FEES IN Agency Mortgage Corporation American Enterprise Bank of Florida Bank of America, N.A Countrywide Home Loans East West Mortgage Company, Inc E-LOAN EverBank First Transcontinental Financial Group Corp Garden City Mortgage Greater Rochester Mortgage Corporation Home Financial Services Inc Lake City Mortgage Madrate.com National Mortgage Alliance Priceline Mortgage Quicken Loans The Money Store Total Group Trident Capital Funding Union State Bank VirtualBank

110 30-YEAR REFINANCE PORTLAND (OR) LENDER APR RATE FEES IN AAXA Discount Mortgage AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Bank of America, N.A Countrywide Home Loans Double T Mortgage, Inc East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank Hart West Financial, Inc Mortgage Capital Associates Mortgage Integrity National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Providers Financial, Inc Quicken Loans Sammamish Mortgage Stashin Mortgage Services, Inc The Money Store

111 30-YEAR REFINANCE SAN FRANCISCO LENDER Total Mortgage Services APR RATE 5.5 FEES 8500 IN VirtualBank AAXA Windsor Discount Financial Mortgage Corporation Absolute Your Best Mortgage Rate Financial Company Action Residential Mortgage Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC American Lending Group Inc Amerimac Plaza West Financial Amerisave Amstar Mortgage Corp Avant Lending Group, Inc Bank of America, N.A Capital Network Funding Consumer Mortgage Services, Inc Countrywide Home Loans Daylight Discount Mortgage E-LOAN Emortgages.com Epix Funding EverBank First Equity Direct First National Mortgage Sources First National Mortgage Sources Global Mortgage Hamilton National Mortgage Co J.D.P. Mortgage Madrate.com Mortgage Capital Associates NationsChoice Mortgage One Easy Fee Home Loans One Mortgage Network, Inc Pacific Choice Mortgage Priceline Mortgage Providers Financial, Inc Quicken Loans SecureLend.com The Money Store

112 15-YEAR PURCHASE MORTGAGE ALBUQUERQUE LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com Amera Mortgage Corporation American Enterprise Bank of Florida American Lending Group Inc Amerisave Bank of Albuquerque Bank of America, N.A Caprock Lending Countrywide Home Loans Daylight Discount Mortgage ebank Mortgage E-LOAN EverBank First Community Bank Guaranteed Rate, Inc LoansAtWholesale Mortgage Capital Associates Mortgage Integrity National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans The Money Store Wells Fargo Bank Your Best Rate Financial

113 15-YEAR PURCHASE MORTGAGE BOSTON LENDER APR RATE FEES IN APR AAXA The Money Discount Store M ortgage AFI Watertown Financial Savings Bank Agency Windsor Mortgage Financial Corporation Mortgage Corporation AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Amstar Mortgage Corp Bank of America, N.A Belmont Savings Bank Century Bank Citizens Bank of MA Countrywide Home Loans Digital Credit Union East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First New England Mortgage Corp First Transcontinental Financial Group Corp Homeland Financial Mortgage Co(BR) HomeQuest Mortgage, Inc Madrate.com Massachusetts Discount Mortgage Middlesex Savings Bank Mortgage Capital Associates National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans Powder House Mortgage Co., Inc Priceline Mortgage Quicken Loans Rockland Trust Company Salem Five Cents Savings Bank Select Financial Mortgage Corp Source Funding Corp Sovereign Bank Star Mortgage TD Banknorth Massachusetts

114 15-YEAR PURCHASE MORTGAGE CHARLOTTE LENDER APR RATE FEES IN APR AAXA Discount Mortgage Abba First Mortgage Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida Amerisave Bank of America, N.A BB&T Carolina Equity Services, Inc Countrywide Home Loans Daylight Discount Mortgage East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First Charter Bk Guaranteed Rate, Inc Mortgage Capital Associates National Mortgage Alliance Olympic Mortgage Consultants, Inc Priceline Mortgage Quicken Loans Wachovia Bank

115 15-YEAR PURCHASE MORTGAGE CHICAGO LENDER APR RATE FEES IN APR AAXA Discount Mortgage Agency Mortgage Corporation AimLoan.com Allstar Home Mortgage, Inc Amerisave Bank of America, N.A BankFinancial Chase Bank Countrywide Home Loans Downey Savings & Loan Assoc., FA ebank Mortgage E-LOAN EverBank Fifth Third Bank First Savings Bank of Hegewisch Guaranteed Rate, Inc Harris National Association JC Financial, Inc LaSalle Bank Liberty Bank for Savings Madrate.com Marquette Bank MB Financial Bank, NA Mid America Bank Mortgage Capital Associates National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Sterling Home Mortgage The Money Store Washington Mutual Bank World Savings Bank

116 15-YEAR PURCHASE MORTGAGE DENVER LENDER APR RATE FEES IN APR AAXA Discount Mortgage Absolute The Money Mortgage Store Company Agency Washington Mortgage Mutual Corpora Bank tion AimLoan.com Wells Fargo Bank American World Savings Interbanc Bank Mortgage, LLC American Your Best Lending Rate Financial Group Inc Amerisave Amstar Mortgage Corp Bank of America, N.A Bank of the West Camelot Mortgage Group, Inc Castlewood Home Loans Chase Bank Countrywide Home Loans Custom Home Lending Daylight Discount Mortgage DNL Mortgage Authority, Inc Downey Savings & Loan Assoc., FA Eagle Lending Corporation East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First Transcontinental Financial Group Corp Guaranteed Rate, Inc Hart West Financial, Inc KeyBank Liberty Savings Bank LoansAtWholesale Madrate.com Mortgage Capital Associates Mortgage Integrity MortgageMint National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans

117 15-YEAR PURCHASE MORTGAGE HOUSTON LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Austin First Mortgage Bank of America, N.A Caprock Lending Chase Bank Compass Bank Earth Mortgage E-LOAN EverBank Franklin Bank, S.S.B Guaranteed Rate, Inc LoansAtWholesale Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Renaissance Mortgage Washington Mutual Bank Wells Fargo Bank World Savings Bank

118 15-YEAR PURCHASE MORTGAGE KANSAS CITY LENDER APR RATE FEES IN APR aasent mortgage corporation AAXA Discount Mortgage ABI Mortgage, Inc AimLoan.com American Interbanc Mortgage, LLC American Lending Group Inc Amerisave Amstar Mortgage Corp B&L Bank Bank Midwest Bank of America, N.A BankLiberty Capitol Federal Commerce Bank Countrywide Home Loans ebank Mortgage E-LOAN EverBank First Federal Bank First National Bank of St. Louis Guaranteed Rate, Inc Mortgage Capital Associates Mortgage Integrity National Bank of Kansas City National Mortgage Alliance North American Svgs Bk One Easy Fee Home Loans Premier Mortgage Funding, Inc Priceline Mortgage Quicken Loans Total Mortgage Services U.S. Bank UMB Bank Your Best Rate Financial

119 116

120 117

121 15-YEAR PURCHASE MORTGAGE MADISON LENDER APR RATE FEES IN APR AimLoan.com Amerisave AnchorBank, FSB Associated Bank Bank of America, N.A Centurion Financial Group Chase Bank Countrywide Home Loans ebank Mortgage E-LOAN EverBank First Wholesale Mortgage of Wisconsin Guaranteed Rate, Inc Hartland Mortgage Centers, Inc Integrity Mortgage Group, LLC Madison Financial Madrate.com Mortgage Capital Associates National Mortgage Alliance Priceline Mortgage Quicken Loans The Money Store U.S. Bank Wisconsin Wholesale Mortgage

122 119

123 15-YEAR PURCHASE MORTGAGE NEW YORK LENDER APR RATE FEES IN Agency Mortgage Corporation American Enterprise Bank of Florida Astoria Federal S&LA Bank of America, N.A Citibank, NA Concord Mortgage Corp Countrywide Home Loans East West Mortgage Company, Inc E-LOAN EverBank First Trade Union Bank First Transcontinental Financial Group Corp Garden City Mortgage Greater Rochester Mortgage Corporation Home Financial Services Inc HSBC Bank USA, N.A Lake City Mortgage Madrate.com Mountain Mortgage Corp Municipal Credit Union National Bank of Kansas City National Mortgage Alliance North Fork Bank Priceline Mortgage Quicken Loans Sovereign Bank State Farm Bank The Money Store Total Group Trident Capital Funding Union State Bank Washington Mutual Bank

124 15-YEAR PURCHASE MORTGAGE PORTLAND (OR) LENDER APR RATE FEES IN AAXA Discount Mortgage AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Bank of America, N.A Countrywide Home Loans Double T Mortgage, Inc Downey Savings & Loan Assoc., FA East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank Guaranteed Rate, Inc Hart West Financial, Inc KeyBank Mortgage Capital Associates Mortgage Integrity National Bank of Kansas City National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Providers Financial, Inc Quicken Loans Sammamish Mortgage Stashin Mortgage Services, Inc The Money Store U.S. Bank Washington Mutual Bank Wells Fargo Bank

125 122

126 15-YEAR REFINANCE ALBUQUERQUE LENDER APR RATE FEES IN APR AAXA Discount Mortgage AimLoan.com Amera Mortgage Corporation American Enterprise Bank of Florida American Lending Group Inc Amerisave Bank of America, N.A Caprock Lending Countrywide Home Loans Daylight Discount Mortgage ebank Mortgage E-LOAN EverBank LoansAtWholesale Mortgage Capital Associates Mortgage Integrity National Mortgage Alliance One Easy Fee Home Loans One Mortgage Network, Inc Priceline Mortgage Quicken Loans The Money Store Your Best Rate Financial

127 15-YEAR REFINANCE BOSTON LENDER APR RATE FEES IN APR AAXA Discount Mortgage AFI Financial Agency Mortgage Corporation AimLoan.com American Enterprise Bank of Florida American Interbanc Mortgage, LLC Amerisave Amstar Mortgage Corp Bank of America, N.A Countrywide Home Loans East West Mortgage Company, Inc ebank Mortgage E-LOAN EverBank First Transcontinental Financial Group Corp HomeQuest Mortgage, Inc Massachusetts Discount Mortgage Mortgage Capital Associates National Mortgage Alliance One Easy Fee Home Loans Priceline Mortgage Quicken Loans Source Funding Corp The Money Store Windsor Financial Mortgage Corporation

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