Compliance professionals have been consumed by TRID for the past eight months, and with good
reason. The magnitude of change TRID
has spurred in the mortgage industry is
unparalleled in recent memory, and only
recently has the Consumer Financial Protection Bureau (CFPB) acknowledged
that the rule has been less than clear in
Being immersed in the day-to-day
challenges of ensuring compliance with
TRID is certainly the highest and best
use of compliance professionals’ time.
However, TRID is but one aspect of a
much larger concern, one which compliance professionals may be overlooking:
the consumer experience.
TRID is part of the CFPB’s larger
“Know Before You Owe” initiative, the
goal of which is to provide consumers
with better education and more transparency and, ultimately, more fairness
during the mortgage process. It’s a
laudable goal, to be sure; however, one
might feel about the CFPB’s execution.
What’s come out of this initiative, which
also includes the eClosing pilot, is a clear
directive from the CFPB to lenders to put
the consumer first in the transaction.
This isn’t some passing fancy. Every action the CFPB has taken since its inception
has been driven by this “consumers first”
mandate. Take, for example, the CFPB’s
reaction to Quicken Loans’ Rocket Mortgage launch during the Super Bowl.
The intent behind Rocket Mortgage
isn’t to push consumers into a bad loan
before they fully understand the product
or process. It’s to make the mortgage ap-
plication and qualification process easier
and more streamlined for those borrowers
that would unequivocally qualify. However,
the CFPB was quick to warn consumers on
Twitter, “When it comes to #mortgages,
take your time, ask questions and #know-
“Ability to Repay.” “Unfair, Deceptive,
or Abusive Acts or Practices (UDAAP).”
“The 2013 Mortgage Servicing Settle-
ment.” At every step, the CFPB has tele-
graphed its expectations to the industry.
Not Just About
BY MARK McELROY
TRID is but
of a much