The assessment and report are required by the Dodd-Frank Act, which created both the CFPB and the requirements that became the TRID Rule. The CFPB also requested public comment on the effects that the TRID Rule has had on various aspects of the residential mortgage market. Comments are due no later than January 21, 2020.
Of interest to the mortgage industry, the CFPB specifically requests comment on the implementation costs and ongoing costs to the industry of compliance with TRID, its effect on lenders’ ability to sell loans in the secondary market, and its effect on the way lenders disclose information to applicants. In order to assess whether initial disclosures have become more effective or timelier after TRID, the CFPB indicates that a ‘consumer-level dataset’ covering periods before and after the implementation of TRID would be ‘informative.’
The ‘ideal’ dataset would include the type of disclosure, disclosure date, whether it was re-disclosed and the reason for the re-disclosure, and the information disclosed, such as loan terms, structure, fees, and closing costs. In order to assess the effect of TRID on mortgage markets generally, the CFPB requests information on whether the TRID Rule affected price or volume of mortgage origination by product type (construction, subordinate liens, or manufactured housing loans, for example), whether it caused any entry, exit or consolidation in any parts of the market, and whether it changed the relationship between lenders and other service providers, such as settlement agents or lender affiliates.
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