An anniversary is a time where one looks back on the previous year, bask- ing in that nostalgic glow,
while reminiscing on all those moments that define the special day. For
some, an anniversary is a happy time.
That first year of marriage, perhaps.
The honeymoon period, where
everything is still new, fresh, exciting, and fun. For others,
however, an anniversary brings on a flood of depression,
sadness, and a feeling of uncertainty.
It should not be difficult to figure out where the anniversary of Know Before You Owe (KBYO) falls into the
above scenario. As the mortgage industry approaches
the first year of full implementation with the Truth in
Lending Act-Real Estate Settlement Procedures Act Integrated Disclsoure (TILA-RESPA Integrated Disclosures
or TRID) rule (Rule), many are looking back on the last
12 months as some of the most complicated, stressful, and confounding months since the collapse of 2008.
Most of us still have many questions, and many more
are just now feeling the effects of incorrect application
of the Rule, as they go through Federal, State, and other
By Leora Ruzin
A Year Later:
THE TRID HANGOVER
A look at the mortgage landscape
a year after the implementation
of Know Before You Owe
According to the Ellie Mae July 2016 Origination Insights Report1, the average days to close has held steady
at 46 days, which is a far cry from January 2016, when
the average days to close was at a high of 50 days. Every
day that can be shaved off a loan cycle can equate to improved customer service scores, reduced lock extension
fees, and an overall smoother process. So, how has the
industry responded to the changes in the loan process
as a result of KBYO, and how have lenders endured the
ever-present war between investors and document providers on how the Rule should be interpreted?
For many lenders, the tendency to over-document
has become the norm, and loan files are filled to the
brim with Loan Estimates. The motto has become “when
it doubt, redisclose!”, and while this may seem like a
no-brainer, the result of this knee-jerk reaction is regulators auditing your files and asking you why. Why did you
redisclose if you were only correcting the spelling of a
settlement agent? If there is no 10% tolerance violation,
why did you redisclose after you updated the title fees?
How come you are applying the mailbox rule to every
redisclosure even though your borrower has opted for
The reason why many lenders are going with this approach is simple. Different aggregators have spent hours ∆