It’s been well over a couple of months since TRID was thrust upon us, and we’re starting to generate a better picture of how lenders are viewing the various requirements, and the variety of implementation of the rule.
One thing that can be said, unequivocally, is the consumer has been sorely tested, and terribly wronged. None of what this set of rules promised can ever assist them in better understanding their transaction. And, conversely they are merely footing the bill for adding additional staff monitoring compliance, the invention of a new department that issues Closing Disclosures, and an overall nervousness on the secondary market from investors who lack the complete understanding of what should be in a loan file, and how it should have been originated.
The unfortunate part of all of this is that we in the business can adapt to handle whatever is thrown at us, and aside from forcing us into incompetence, we don’t believe our clients will. A straightforward transaction has now taken on a whole new persona with less common sense, and more confusion. We live and breathe mortgage transactions and well understand the premise, but the laymen haven’t a prayer of comprehension of the incessant over-disclosure.
Given one of the goals was to slow down the transaction by adding additional wait periods, the most amusing part for me is our clients are the ones asking if I can hurry things up a bit! When I explain about the three days wait periods at various points in the process, many have asked if they can sign something that allows us to waive it! I would, of course, love to have that ability, but short of a major catastrophic event that is life threatening in nature, that isn’t going to happen.
So, how do we make this go away? Or, at least cause an effective change that positively impacts loan transactions? How can we ensure that the CFPB, and the powers that enforce this rule, realize how much it has negatively affected our consumers? If enough people shout about it will it actually be heard? It does need to change. The new forms and disclosures are wonderful, and held so much promise. But, the implementation is sadly lacking and has turned a dream into a nightmare.
Suzanna Ravin has been working in the lending industry for the last twelve years, currently managing a retail branch Peak Mortgage, a division of Finance of America Mortgage, LLC. She maintains her top originator status by remaining very hands-on with her clients’ transactions. Often referred to as the Loan Guru, she loves to be completely informed on lending guidelines, and regulations.