TRID Can Unfortunately Kicked Down the Road
It’s Friday, a typically busy day for us in the title business. We have five loan closings on the schedule – five families about to complete the home buying journey. This should be an awesome day! The awesomeness, though, is already tarnished. Why? Great question! And the answer is why we are sorely disappointed that the CFPB has decided to kick the TRID can down the road.
TRID delay keeps closing tables empty . . . .
Of the five loan closings on our schedule today, only one is ready to go. That’s right . . . only one. On the other four, we are still waiting for closing instructions and documents from the buyers’ lenders. That means that four eager home buyers do not know whether or not they will be able to close today. Four eager home buyers do not know how much money they need to wire to complete their purchase. Four eager home buyers do not know whether they will be able to unload their moving trucks today. This scenario creates tons of stress for consumers, who should feel nothing but excitement about their closing. Yet it happens every day; and it is, by far, the worst part of what we do – having no control over something that causes unsuspecting consumers so much stress.
For us, the best part of the new TILA-RESPA Integrated Disclosures (TRID) rule addresses this annoying and stress-inducing phenomenon. Initially effective on any loan application made on or after August 1, 2015, TRID requires creditors (mortgage lenders) to deliver the Closing Disclosure form to consumers (buyers/borrowers) at least 3 days prior to “consummation” (under the final rule, the Closing Disclosure replaces the HUD-1 settlement statement and the final Truth in Lending Disclosure). That means no more Fridays like today; no more poor buyers waiting helplessly on the day of closing for final figures; and it should mean improved experiences for every party to the transaction. Because of that, we were really looking forward to the implementation of the rule, warts and all.
On Wednesday, the Consumer Financial Protection Bureau announced that it would delay the effective date of the rule to October. Most of our industries’ advocacy groups have heralded the decision as ideal for consumers, the thought being that the complexity of the changes would interfere with closings. No doubt, there will be some hiccups. They’ll be there in October as well. In the meantime, we’ll be here, with empty closing tables, waiting for closing instructions and helping to manage buyers’ stress.
