Amendments aimed at clarifying the TILA-RESPA integrated disclosure rule have gone into effect and the Consumer Financial Protection Bureau's consideration of additional clarification some mortgage companies want is moving forward.
Mortgage companies that are ready to fully implement the changes can start now, but they don't become mandatory until Oct. 1 of next year.
"If you start you have to be consistent, or you could just wait until 2018," said Mike Vitali, chief compliance officer at LoanLogics.
The recent publication of a small entity guide codifies and implements the amendments, but some think the CFPB still hasn't done enough to address a "black hole" created by closing delays, the additional comment period for which just ended, said Vitali. Black holes are circumstances where mortgage companies can't accommodate additional costs because of a provision of TRID that limits how much fees can change.
"These clarifications are not significant as far as anything that is going to make the process easier for a consumer," said Valerie Saunders, executive director of the NAMB, a trade group that represents mortgage professionals who primarily focus on the origination side of the business. "The real issues remain."
Although mortgage companies continue to push for clarification on a couple points, they generally are far less concerned about TRID compliance than they were when they rule first came out in October of 2015.
"The black hole still exists and lenders still are fearful the CFPB could penalize them for rules that are not well defined, but the TRID issues have not caused many kickbacks recently," said Tom Millon, president, CEO and chairman of the Capital Markets Cooperative, a subsidiary of Computershare that works with smaller lenders.
"Certainly TRID caused the cost to originate to rise but there haven't been any material issues for quite some time," he added.