Amid all the hype, I have to admit, when I heard originally that the government were changing the old Good Faith Estimate and Truth in Lending disclosures to something new and easy to read, I was pretty darned excited. I had no problem with the old forms, it was easy to explain it to our clients, however they certainly had need of simplification. We were led to believe the buyer on a purchase transaction would no longer have to view the entire set of fees paid by the seller as ell as their own fees, and therefore would have just their own cash to close figures disclosed. As with all the rule and laws changes we have been subject to over the last couple of years, I wholeheartedly embraced the new forms, learned them inside out, and read the majority of the TRID disclosures “handbook.”
You can only barely comprehend my utter disappointment when, after the first couple of weeks with little issue, the whole premise of the new disclosures was suddenly deemed incorrect, and we did in fact have to include seller paid items. We also now have to disclose the non-discounted Lenders Title Policy, that,to be perfectly honest, we had no idea even existed before now. None of the industry veterans I’ve spoken with have ever been privy to this hidden fee. We now have to make up a “fake” credit to offset the full fee, regardless of who is paying what.
Not only this, but literally every time something changes by a dollar, we send yet another Change of Circumstance disclosure out to the clients, which quite frankly has seen our clients become so impatient with constantly having to click on links to acknowledge them, that they’re not reading anything by this point, and merely want the transaction to close.
What had such potential has now taken on additionally more complex calculations, requiring, for the laymen, higher than average intelligence to truly grasp what we are now disclosing to them. – sounds familiar? I feel a good dose of deja vu coming on!
What are we really trying to prevent here with all this additional ruling? To hinder the borrower from truly understanding their transaction? To discriminate against those borrowers that don’t like clicking to sign forms and prefer ink signing real paper documents? To invent some random never seen before fees charged by title companies, and then offset them with a fake credit? To slow down the process so much should there be a change in anything (likely nothing that can be avoided, but is a genuine part of the transaction), that the buyers miss their closing date, the sellers are upset, and nobody really understands why as they all just really want to close?
I fear the industry is in danger of losing many true professionals that have ridden every storm thrown at them over the last few years, those of us that care immensely about our clients, that have a loyal following of clients and referral business as we have done our very best regardless of the obstacles, and for what? Those that are left are wrangling with yet another rule change tragedy, with ever increasing costs that are passed on to their clients to pay for the overwhelming compliance staff required to police files, and, more distressing, grey hair, untold digestion issues, depression and stress. Can somebody please properly evaluate what the end goal is, and let us get back to the original premise of these new and improved forms so we can really do justice to our clients?
Suzanna Ravin has 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 .