Comment on TRID proposal

To date, there have been 552 comments posted on the proposed TRID rules. About 90 percent are form letters that start:

I am a title insurance professional and I am contacting you today about the proposed rulemaking on TRID. [Insert your personal experience with the Closing Disclosure here]

Many submitters just left the bracketed info in the form letter and had no additional comments other what else the letter had in in it:

"The CFPB missed an opportunity to change the Closing Disclosure's calculation of title fees. Consumers around the country continue to receive inaccurate information at the closing table about their title insurance costs. This provision of the rule defeats the Bureau's own mission to provide consumers with a better understanding of their transaction.

I urge you fix this problem immediately so consumers have a clear understanding of the cost of their real estate transaction."

I also really liked this one- really on point from a TRID perspecitve:

"Everything regarding the mortgage industry is horrible right now. It is horrible trying to keep all of these [censored] documents and rules straight. The hard working people trying to help borrowers continue to struggle. The borrowers are frustrated because the government required appraisal management companies are doing a bad job. I do not know exactly how many borrowers I lost because of the poor performance of these AMCs......."


Censored = the actual word BS. Really?? Government mandated AMCs?


I surely hope that the banking industry has a little more class and can give the CFPB some meaningful input

I look forward to reading your letters.

Amen. Just how much credence do the title insurance people expect the Bureau to put into their sloppy form=letter comments?

There were more pluses than minuses in the proposed TRID changes, IMHO. Bankers, warm up your keyboards and comment!

Of course, the Bureau hasn't even published the rule in the FR yet. With an October 18 comment deadline, I'm betting on a September 16 publication date (32 days before comments are due).

There are already 500+comments and the proposal hasn't been officially published yet? Am I reading that right?

652 received - only 552 currently available for public viewing. There appear to be a whole slug of them from real estate agents also saying nothing but one or two lines stating they should be automatically entitled to the closing disclosures.

John,

The proposal was published in the FR on August 15.

https://www.gpo.gov/fdsys/pkg/FR-2016-08-15/pdf/2016-18426.pdf

Thanks, Randy!

And I'm not at all surprised about the Realtor comments!

Drat! I took my birthday off from work and they snuck it by me! Thanks, Randy.

What they haven't yet published is the final rule amending the servicing rules that was approved August 6.

Thanks for sharing Randy. I have not yet looked at any of the comments. Hope to submit one myself pretty soon!

I'm reading through the original comments, and I'm sadly not shocked that even those in the mortgage industry don't understand TRID at all. I just read one from a loan officer that said the "settlement statement takes precedence over the CD" so he tells his borrowers to ignore the figures on the CD

This one is my favorite:

TRID and the CFPB should be dismantled and Barney Frank prosecuted for grave conflicts of interest.Is it not true that Barney Frank the sponsor of the Dodd Frank owns an appraisal management company? IS it not true larger banks contributed to Clinton Foundation? Is it not true that banks have different more lenient standards and have been allowed to basically and wrongfully use the government REGS to squeeze hardworking honest local businesses and mortgage brokers? Is it not true that commercial banker can charge local businesses 100's of percent or whatever they can convince the business to take? Only thing good was a federal registry however this system is still seriously flawed. Banks should have same regulations and challenges met with a local broker. We have been categorized and hurt wrongfully. I had five loan officers and now forced to operate with just myself . We do the processing yet unable to be compensated for work that is necessary and critical. YET BANKS CAN HIDE THIS IN COSTS! We have kept this business to help the public and give them choices but is now actually costing us money to run. I do not run the business from my home . I have street costs just like every local business and bank.

Last week to post comments. I posted mine today. Not a lot of comments from financial institutions. Speak now or forever hold your peace...

I'm up to 10 pages. Planning on posting Monday.

11 Pages - sent this morning. I will update when posted on-line.

Thanks, Randy.

Posted:

https://www.regulations.gov/document?D=CFPB-2016-0038-1376

Well done sir! Thank you for sharing!

Most excellent comment letter. Just hope the bureau can get its act together and take up some if not all of your ideas.
Thanks rl. Just found this.