Bank of America’s new No Fee Mortgage Plus (NFMP) program for home purchasers collapses all lender fees into one combination of interest rate and points, eliminating the myriad of separate lender "junk fees" that confuse shoppers. Junk fees are also a source of abuse by less scrupulous lenders who may raise them at the 11^th hour.

B of A is not unique in eliminating junk fees. Upfront Mortgage Lenders (UMLS, there are now 7 listed on this site) also commit to a single guaranteed fee, but B of A is the largest, and hopefully it will induce other large players to follow suit.

An even more impressive feature of NFMP is its absorption of all private third-party charges, including title insurance, mortgage insurance, appraisal costs and credit report. B of A even pays for the buyer’s title policy. All these third party costs as well as its own costs are covered in the rate and points.

Are NFMP Loans a Good Deal?

The fact that B of A pays all third party charges doesn't necessarily mean that NFMP loans are bargains. The only way to determine whether they are or not is to shop them against other lenders on-line, and B of A makes this very difficult.

Their web site is designed to induce you to call them, not shop them. To find prices, you have to learn that the "Calculator" button provides the path, which takes some doing. When you get there, you find that B of A has narrowed your selection to only 3 combinations of interest rate and points for each of 7 programs. (Good web sites offer as many as 10 times that number). This winnowing down of choices might be acceptable, even desirable, if it were based on relevant borrower characteristics, such as their expected period in the house, or their tax bracket, but it isn’t.

Further, you can’t shop adjustable rate mortgages (ARMs) with confidence because the site does not disclose the index, margin, rate caps or maximum rate. And borrowers who cannot provide full documentation, or whose credit is not "good", can’t price their loans on the B of A site because the site does not adjust prices for these factors.

I worked within these limitations to compare B of A’s prices with those of a UML which discloses a very wide range of rates that allowed me to find matches for the few rates shown by B of A. In the comparisons, I selected common interest rates and compared the B of A points with the sum of lender fees and third party fees at the UML.

The results were mixed. In the 11 comparisons I did, B of A’s prices were lower in 5 and higher in 6.

The bottom line is that B of A’s inclusion of all lender junk fees and third party fees into a single price does not necessarily mean that a B of A price is lower than that of its competitors. It all depends on the particular market niche in which the borrower falls, and B of A’s price in many if not most niches can’t be shopped on-line.

B of A’s loan officers still have the right to charge an overage – a price higher than the price posted by the company. Overages and price secrecy are vestiges of the bazaar culture that has long dominated mortgage banking. B of A has taken a big step away from the bazaar, but it still has a way to go.

Will the Bank of America Model Be Copied?

If B of A’s example is followed by other lenders, or if it emboldens legislators to mandate it for all lenders which I have long advocated, its importance cannot be overemphasized.

Under existing arrangements where borrowers pay the third party fees, lenders have had no incentive to use their buying power to lower them. But once lenders are on the hook for these charges while competing with each other for loans, they will use their superior information and buying power to drive down prices. The incremental cost of third party services included in the lender’s price will be much lower than the prices borrowers now pay when purchasing them separately.

Copyright Jack Guttentag 2008