Friday, April 22, 2016

UPDATE: SIX MONTHS INTO TRID REQUIREMENTS



It’s a new day!

Six months into the new TRID rules and in my experience and opinion, the transition appears to be going pretty smoothly. The Lenders issuance of their Loan Estimate and Closing Disclosure, along with complying with disclosure requirements seems to be working out too. Most Lenders I am working with are ready to close on time (many before the date of closing). Perhaps due to concerns of delayed closings and the possibility of disappointing their Clients has them working harder and expediting every file (which is GREAT NEWS!)

While there have been internal hiccups with computer software, at banking institutions and escrow companies, we are working around them. For the most part, this has not affected our Clients and the closing of their transactions. We continue to rely on our tried and true methods of operation for closing transactions, while some of the larger institutional Lenders are still working on getting their automated systems up and operating (they appear to be having continued difficulties). Again, this has not affected my transactions to date, though may affect others.

In my humble opinion, I expected the Escrow Industry to shoulder a heavier burden due to the new TRID requirements, though, in my personal experience, I have found that the Lenders are acting more independently and are carrying their own burden (which in years past is not the norm). Lenders and Mortgage Brokers had increased their demands on escrow holders to such an extent, Escrow Companies spent an extensive amount of time responding to repetitive (and quite frankly excessive and burdensome) requests for revised documentation. As of right now that process is being kept outside of escrow and in the lenders office, where it rightly belongs. However, I reserve the right to amend this statement in future, as it will not surprise me if, in time, Lenders and Mortgage Brokers shift more responsibilities and burden to escrow, as it has always been their M.O. (modus-operandi).

My hope is that things will continue to move in a positive direction. We do have a few challenges in the Industry and I have been doing some volunteer work with the Escrow Institute of California. The nice thing is that I know a lot more of what is happening in the Industry in California, as well as the nation. The Escrow Institute of California’s Board members are some of the most sophisticated and intelligent people I have ever met! In May 2016, they will personally meet with congressional representatives in Washington D.C. and lobby support and awareness for California’s Department of Business Oversight’s Escrow Licensees, whose members are one of the nation's most highly regulated (and ironically Lenders are demanding of additional and unnecessary regulation).

We are living in an exciting time, dealing with changes that have been thrust upon us. Many in the Industry, myself included, have tugged along providing services just like in years past. It is now that we must wake up and open our eyes! We must stay informed and connected. To educate ouselves and do all that we can to continue to be a strong, relevant mainstay in our communities and Industry.

You may find the following links of interest:

Consumer Financial Protection Bureau (CFPB) http://www.consumerfinance.gov/


Escrow Institute of California http://www.escrowinstitute.org/

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