CRE would like to express its appreciation for the many comments it received on Private Transfer Fees. Subsequent to the CRE review of the public comments it received, CRE prepared a draft recommendation for”Internal Review” attached herewith entitled “CRE Draft Recommendations for Internal Review”.
Two comments in the public record defined the boundaries of the debate, a comment from the Federal Home Loan Bank of New York and the comment of Freehold Capital Partners. CRE sent its draft recommendation to both of the aforementioned parties for comment.
Freehold Capital Partners sent CRE a detailed response set forth in the attachments hereto entitled “Freehold”
CRE then prepared its draft recommendation entitled “CRE Draft Recommendations Transfer Fees”
Given the constantly changing data base, CRE has decided to present its draft recommendations for public comment prior to making its final recommendation to Federal and State regulators.
Please provide your comments in the “Submit a Post” section of the Private Transfer Fee Forum
CRE Draft Recommendations Transfer Fees 11.15.
After reading the CRE recommendations and the Freehold response I have difficulty believing that the CRE is acting in an unbiased manner. It’s actions lead me to question the value of the CRE. Whose best interest is the CRE acting in? It does not appear to be that of the public.
I would also like to know the amount of money that ALTA and the NAR have contributed to the CRE.
Almost 100% of the responses are for the free market to determine if the concept works (which 20 years or more have proven that it has). Freehold provides logical and simple responses to CRE draft responses, yet the CRE continues to “drill’ the same ALTA and NAR illogical bullet points. Interesting?