Checkout the weak justifications for builder owned ABA’s at www.regulations.gov and search on FR-5352. You will be directed to comments submitted to HUD regarding its Advance Notice of Proposed Rulemaking – Strengthening and Clarifying RESPA’s “Required Use” prohibition.
I was happy to see comments disapproving of ABA’s, even from real estate agents. And of course, the many comments in support of ABA’s. The one-stop shopping mantra and how efficient communication is when the parties are affiliated versus non-affiliates goes on and on. Really? You are kidding me? Do you think the independent providers don’t have email and the technology in place to run an efficient operation? Do independents lack communication skills? Get real.
The deadline for submissions was September 1. Here is what I submitted. Enjoy!

{ 1 comment… read it below or add one }
Francine:
I enjoyed reading your ANPR comments. I thought your comments expressed the simple truth that underlies all controlled business arrangements — that inexorable conflicts of interest make them non-starters.
Keep up the good work!