Realogy and its Subsidiary, Title Resource Group, File RESPA Comments with HUD

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Companies Express Concerns that Proposed RESPA Rule Changes Will Not Benefit Consumers and Instead Create Anti-Competitive Effects That Will Adversely Affect Settlement Service Providers

June 16, 2008 // Franchising.com // PARSIPPANY, N.J. & MT. LAUREL, N.J. — Realogy Corporation, a global provider of real estate and relocation services, and its subsidiary, Title Resource Group (TRG), a full-service title, settlement and vendor management services company, each filed their formal comments with the Department of Housing and Urban Development on proposed rules to amend the Real Estate Settlement Procedures Act (RESPA). While appreciative of HUD's efforts and objectives, Realogy and TRG are opposed to the proposed RESPA rule changes as written, and have requested that HUD carefully reevaluate the unintended, as well as the practical, consequences of the proposed rule changes.

"While we generally support HUD's stated objectives for RESPA reform, we are concerned that certain aspects of the rule are anti-competitive, would discourage consumer shopping and do not simplify or clarify consumer disclosures," said Realogy President & CEO Richard A. Smith. "We also question the timing of the rule and urge the Department to consider the compliance costs for many settlement businesses that are challenged to remain operational in the present housing market."

Realogy believes that consumers will benefit from more transparency in the settlement process and disclosures that encourage consumers to shop for settlement services. However, the Company also believes that the proposed changes in disclosures are overly complicated and ultimately will create anti-competitive effects that are not in the best interests of the consumer.

As a settlement company that does business across the nation, TRG knows firsthand the difficulties consumers often experience at the closing table. "We commend HUD for its focus on simplifying consumer disclosures and attempting to clarify the settlement process," said Don Casey, president and CEO of Title Resource Group. "We are concerned, however, that in its zeal to improve the process, HUD has overlooked several practical components of the rule. For example, we believe the proposed closing script will alter the way closing agents currently deliver settlement services in such a way that could have adverse consequences for the consumer – specifically, increased time spent and fees paid at each closing."

"In summary, we believe that HUD needs to take the additional time necessary to ensure that any changes to the RESPA regulations are indeed improvements and that its efforts should focus on fostering a competitive marketplace," said Smith. "Such an environment inevitably will encourage consumer shopping for settlement services and lower costs to consumers."

The formal comments submitted by Realogy and TRG echo the comments previously filed by various associations including the American Land Title Association (ALTA), the Real Estate Services Providers Council, Inc. (RESPRO), and the National Association of Realtors (NAR).

The formal comments filed by Realogy and TRG are available upon request. The comments will also be posted online at www.regulations.gov.

About Title Resource Group

Title Resource Group (TRG), a subsidiary of Realogy Corporation, is a full-service title, settlement and vendor management services company serving real estate companies, corporations and financial institutions in support of residential and commercial real estate transactions. Headquartered in Mount Laurel, N.J., TRG (www.trgc.com) has 2,100 employees and 420 offices and is licensed in 43 states and the District of Columbia.

About Realogy Corporation

Realogy Corporation, a global provider of real estate and relocation services, has a diversified business model that includes real estate franchising, brokerage, relocation and title services. Realogy's world-renowned brands and business units include Better Homes and Gardens® Real Estate, CENTURY 21®, Coldwell Banker®, Coldwell Banker Commercial®, The Corcoran Group®, ERA®, Sotheby's International Realty®, NRT LLC, Cartus and Title Resource Group. Collectively, Realogy's franchise systems have approximately 16,000 offices and 307,000 sales associates doing business in 90 countries around the world. Headquartered in Parsippany, N.J., Realogy (www.realogy.com) has approximately 13,000 employees worldwide. Realogy is owned by affiliates of Apollo Management, L.P., a leading private equity and capital markets investor.

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