A survey conducted by consulting firm STRATMOR Group reveals that a majority of lenders would not have been ready for the Consumer Financial Protection Bureau's (CFPB) TILA-RESPA Integrated Disclosures (TRID) rules by the original Aug. 1 deadline, thus justifying the CFPB's recent decision to push the deadline back to Oct. 1.
Results of the firm's most recent PeerViews Survey show that, as of the end of March, many requirements of the new rule had not even been considered by an alarmingly high proportion of lenders.
‘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,’ says Matt Lind, managing director of STRATMOR Group, in a release. ‘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.’
The survey shows that, as of March, only 13.5% of lenders had addressed the ‘Who will generate and send out the closing disclosure?’ question; only 26.1% had addressed ‘When will the closing disclosure be issued?’; and only 26.4% had considered the ‘handling of post-closing review.’
What's more, only 41.8% had considered the ‘scripting of LOs and fulfillment personnel;’ only 23.3% (of wholesalers) were ready in terms of ‘preparation of initial loan estimate;’ and only 34.5% were ready with their ‘post-closing repair procedures.’