The American Bankers Association (ABA) has released findings from its recent 2016 ABA TRID Survey focusing on the TILA/RESPA Integrated Disclosure (TRID) rule’s effect on the residential mortgage lending market. The findings, which can be found here, tell the story of increased processing times, fewer products, and substantial closing delays.

The survey of 548 banker participants was conducted between February 1, 2016 and February 17, 2016 and included banks with a wide array of asset sizes from across a large geographic area. Despite this diverse pool of respondents, the responses relating to the effect of TRID were almost uniform:

• Between 457 and 470 respondents reported additional staff training and compliance hours were required to ensure compliance.
• 50% of respondents have hired or plan to hire additional staff.
• 67% reported increased legal and regulatory costs.
• 77% reported increased delays in closing.
• 73% reported that their Loan Origination System (LOS) still has not been fully updated for the TRID rule.
• 83% reported that they were manually bypassing LOS systems due to system limitations.
• A resounding 94% reported that they would like the current informal grace period for “good faith efforts” to be extended.

Survey participants reported between $300 and $1,000 in additional cost per transaction and 8 to 20 additional days required to close a loan. Based on results so far, whether the TRID rule, as currently structured, will produce the consumer benefits intended by the CFPB is questionable. The CFPB is continuing its efforts to provide clarity on the TRID rule, which we have written about here and here. However, without clear written guidance, as well as amendments to the rule to address issues noted by the industry, it is difficult to imagine the easing of compliance burdens.