October 2015 Market Share Report

November 19, 2015

At the end of October and into November we experienced our first closings under the new CFPB TRID disclosures.? More recent closings are happening smoother as everyone gets familiar with the changes. I thought it important to share with you my takeaways from these initial transactions. My first takeaway is being reminded that everyone in the lending and settlement industry is using new software, with new screens and learning new workflow and timelines. The operative word here is ?new.? Just like athletes, regardless of the amount of training anyone has done, it doesn?t simulate real game speed. Until loan processors and loan closers, loan officers and loan underwriters get fifty or sixty real transactions with real circumstances under their belt, they are going to be slower and less sure of what they?re doing. I see it with my team as well. This will affect the speed at which we all can produce our work; especially for the first few transactions. This learning curve is further slowed by the fact we?ve all be doing transactions under both the new and the old rules. This means a lot of back and forth, hardly the ideal environment to burn new procedures into one?s brain cells. Fortunately that will disappear over the next few weeks. And to no one?s surprise, the CFPB rule, at about 1900 pages, is not being consistently interpreted. This leads to slower processing while alignment between the various stakeholders is achieved. And as various regulators start examining TRID transactions, we can expect even more inconsistent interpretations. I don?t intend to suggest that these issues apply to everyone in the business. They are though, quite prevalent although less so than a couple of weeks ago. You may wish to be proactive in your discussions with your clients so that surprises are minimized during these first few months of implementation.

~ John Bethell