Enforcement of the Truth in Lending and Real Estate Settlement Procedures Act Integrated Disclosures—or TRID—should be delayed to provide for a transition period and minimize negative consequences for consumers, according to testimony from the American Bankers Association before the House Financial Services Subcommittee on Housing and Insurance.
Cindy Lowman, president of United Bank of Michigan in Grand Rapids, Mich., testified on behalf of ABA. Lowman, who also serves as chairman of ABA’s Mortgage Markets Committee, emphasized the importance of implementing TRID properly the first time.
“These new rules affect the entire mortgage-lending industry, including lenders, service providers, appraisers, escrow agents and virtually anyone with a relationship to the mortgage lending process,” Lowman says. “They will significantly reshape the housing-finance market, which comprises a substantial portion of our country’s gross domestic product and touches the lives of nearly every American household. If we do not get this right it will have a negative impact on consumers, banks and the recovery of the housing market.”
Regulatory implementation is further complicated by the fact that most banks—and particularly smaller community banks—rely on vendors for regulatory compliance needs and the accompanying software updates and system upgrades. An ABA survey found that while 74 percent of banks are using a vendor or consultants to assist with TRID implementation, only 2 percent of the compliance systems had been delivered by the month of April. Nearly eight in 10 banks (79 percent) couldn’t verify a precise delivery date or were told they wouldn’t receive systems before June.
“Simply put, there is no realistic way that those banks can adequately prepare for the current August 1 implementation,” Lowman says. “Banks that have not fully implemented by the deadline will have to curtail mortgage lending until systems are in place, delivering a heavy blow to the mortgage market at a crucial time of the year.”
While TRID was intended to simplify the mortgage disclosure process, Lowman emphasized that it could add significant complications that end up costing consumers if it’s not implemented properly. She closed her testimony by expressing the industry’s strong support for a delay of enforcement that would minimize negative impacts on consumers.
“ABA strongly supports the efforts of Chairmen Luetkemeyer and Neugebauer and Representatives Carolyn Maloney and Barr in asking the Consumer Financial Protection Bureau to treat the time period between August 1, 2015, and December 31, 2015, as a hold harmless period for enforcement and liability under the new rules, and to formally announce such a period to ensure that the prudential regulators and secondary market stakeholders do the same,” Lowman says. “ABA thanks Representatives Pearce and Sherman for introducing H.R. 2213, which provides for a hold harmless period. We urge quick action to avoid the potential harm to our mortgage customers.”
For more information, visit aba.com.
