A recent PeerViews Survey released by STRATMOR Group, a consulting firm that helps mortgage banks build profitable mortgage lending operations, showed that some lenders may not have been ready to comply with the original Aug. 1 deadline for the TILA-RESPA Integrated Disclosure (TRID) rule.
“Lenders felt like they were ready, but when asked for specifics about how certain TRID-related tasks would be handled internally, they didn’t have good answers,” said Dr. Matt Lind, STRATMOR Group’s managing director. “This suggests that many lenders may be missing key elements of TRID compliance, particularly in regard to process change, that would have constituted a significant risk if CFPB had not set back its deadline.”
Although the survey revealed that a high percentage of respondents had not considered or decided on certain compliance issues at the time of the survey, it should be noted that the survey results are from late March and may not be indicative of lenders’ current status of preparedness.
The survey asked respondents if they had decided on a variety of issues related to TRID implementation and found that preparation seemed to be severely lacking. When asked whether they had decided who will generate and send out the Closing Disclosure, 13.5 percent said they had; 26.1 percent said they knew when the Closing Disclosure would be issued; 26.4 percent said they decided who would handle post-closing review; 41.8 percent said they had worked out how to handle scripting of LOs and fulfillment personnel; 23.3 percent made decisions regarding the preparation of the initial Loan Estimate; and 34.5 percent said they had post-closing repair procedures. The survey also found that the average additional cost for TRID compliance was estimated to be $159.62 per loan when calculated by the lenders. This estimate was roughly the same across lender types except for credit unions, for which the average cost estimate was $83.33 per loan.
Considering the numbers, STRATMOR said that the administrative error that led the bureau to delay TRID implementation until Oct. 3, 2015 is a “fortunate decision for the industry.”
STRATMOR’s PeerViews program is a fast turnaround, small-survey program that gives senior mortgage executives a unique way to obtain specific qualitative mortgage industry information. All PeerViews surveys are conducted as “blind” surveys, with results aggregated to protect the privacy of participants.
Cover Story: