Does the YSP cover the cost of goods and services?
Let us briefly consider each of these questions. Afterward, a suggestion will be offered that, if implemented, would strongly empower the borrower, fortify the lender and broker relationship, preserve continuity and potency of market forces, and save the YSP. Price discrimination: Can the YSP cause price discrimination? There is some evidence that less sophisticated borrowers and borrowers with certain racial profiles have paid higher loan costs. According to HUD’s Office of Policy Development and Research, “price discrimination has been known to occur,” whereby “loan fees are highly correlated to race and education characteristics, with African-American and Latino borrowers paying an average of $415 and $365 more, respectively, than other borrowers.”5 HUD’s recent, final version of Regulation X revisions,6 designed to create a more level playing field, were in part a response to a regulatory impact analysis—required by the Regulatory Flexibility Act—that stated “there is strong eviden
