2016 ABA TRID Survey
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Summary of Key Survey Findings
The American Bankers Association 2016 TILA-RESPA Integrated Disclosure (TRID) Survey had 548 banker
participants. The banks composed a diverse group both in geography and asset size. The data was collected from
February 1, 2016 to February 17, 2016. This timely survey shows that TRID rule compliance: 1) is still a relevant
problem; 2) continues to impose a heavy compliance burden; and 3) causes customer dissatisfaction through
delayed closings and increased fees and costs. Specific findings include:
•
Many banks have been forced to eliminate certain products, such as construction loans, ARMs, home equity
loans, etc., as the rule does not provide adequate compliance direction
•
Over three/fourths claim that TRID has caused loan closing delays anywhere from one to 20 days
•
Approximately one quarter of respondents have increased the total cost to the consumer to obtain a loan
•
About 50 percent of participants claim they have or will have to hire additional staff to comply with the TRID
rule
•
LOS systems are still being updated and changed as 78 percent of bankers report they are still waiting for
system updates and 83 percent claim they are forced to use manual workarounds
•
An overwhelming 93 percent claim uploading and loan processing times have increased as a result of TRID
implementation
•
A resounding 94 percent of bankers believe the TRID “good faith” grace period should be extended
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2
2
What is your bank’s asset size?
Over $20 billion
$10 billion3%
$20 billion
3%
$1 billion$10 billion
22%
$501 million$1 billion
16%
$301-$500
million
17%
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Up to $50 million
4%
$51-$100 million
7%
$101-$200
million
16%
$201-300
million
12%
3
3
What internal loan compliance review/due diligence processes
did your bank have to adopt to ensure compliance with TRID?
(Check all that apply)
Other (Please describe)
96
Additional staff training
457
Added TRID legal reviews
110
Third party compliance audits
192
Post-closing reviews
368
Pre-closing reviews
403
Additional compliance hours
470
Additional dedicated compliance staff
Other answers include:
•
LOS/software testing
•
Third party training
•
Some have halted originating
TRID compliant loans until
further regulatory clarification
154
No new processes adopted
20
0
100
200
300
400
500
Banker Testimony
“We restructured our loan staff and created dedicated/specialized loan originators and processors who only handle TRID. For a small
community bank, this isn't the best use of our staffing.”
“We decided not to issue loans [that must be TRID compliant].”
“We're delaying any 1-4 [family] originations until all of the "kinks" are worked out.”
“[Our bank has experienced] customer dissatisfaction with delays that are caused by timing requirements.”
“[TRID rules] completely limit our ability to provide our customers the flexibility to manage their current assets and the ability to
purchase new ones.”
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4
Personnel Adjustments
Have you had to hire more staff because
of new TRID Rules?
21%
If yes to the question on the left, how many
additional employees did you add to support
additional TRID burdens?
Over 10
8
29%
5 - 10
3
3-5
26
50%
1-2
Yes
No
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No, but plan to do so in future
118
0
20
40
60
80
100
5
120
140
Legal/Regulatory Consulting Costs
Have your legal/regulatory consulting
costs increased because of TRID?
If yes to the question on the left, what is the
increased consulting cost per transaction?
Unknown
102
Over 100%
4
76% - 100%
2
33%
51% - 75%
67%
8
26% - 50%
53
0% - 25%
171
0
Yes
50
100
150
200
No
For banks that answered “unknown,” many reported a
total additional cost of approximately $5,000, with
some reporting up to $50,000 in additional total costs.
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6
Front-Boarding and Loan Processing
Times
Have your front-boarding and loan
processing times increased on a pertransaction basis?
If yes to the question on the left, by how many
additional hours per loan?
4% 3%
Over 10
8
5 - 10
3
3-5
93%
Yes
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No
Unsure
26
1-2
118
0
50
100
7
150
Are you seeing delays in loan closings
because of TRID?
23%
77%
Yes (By approximately how many days?)
No
Banks reported delays in closing anywhere from one day to 20 days, with an approximate average of 8 days.
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8
Have you eliminated any product offerings
because of TRID?
25%
Most frequent products
eliminated include:
• Construction loans
• Balloon loans
• ARMs
• Home equity loans
75%
• Payment frequency options
Yes
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No
9
How many updates/upgrades have you made to
your LOS systems since October 3, 2015?
Over 100
15
50-100
15
25-50
47
10-25
144
1-10
245
None
4
0
50
None
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100
1-10
10-25
150
25-50
200
50-100
250
300
Over 100
10
Is your LOS compliance fully developed with TRID rules as of
today, or are you still waiting for glitches/problems
malfunctions to be addressed by the vendor?
6%
22%
72%
Yes, ready
No, still waiting for updates
No, and vendor has not promised further updates
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11
Are you instituting manual workarounds for your LOS systems
due to LOS system “bugs” or system limitations/imperfections?
17%
83%
Yes
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No
12
Has total cost to the consumer to obtain a loan (all-in)
changed and, if so, by what percentage since the
implementation of the TRID rule?
25%
35%
40%
Increased
Unchanged
Cannot determine
For those that reported an increase in cost to the consumer, specific percentages ranged anywhere from 1%
to 75%, with an approximate increased cost of 15% per transaction.
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13
Are you charging higher mortgage loan fees to
consumers because of TRID? (check all that apply)
Other (please specify)
58
Closing/settlement fees
65
Lock fees
Other answers include:
9
Appraisal fees
31
Attorney fees
39
Origination fees
67
No
247
0
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50
100
150
200
250
•
Processing fees
•
Administration fees
•
Abstracting fees
•
Title fees
•
Application fees
•
Waiting for further
analysis
300
14
Has your bank incurred losses due to
TRID’s disclosure tolerances?
Yes
172
No
127
Have not measured
102
0
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20
40
60
80
100
120
140
160
180
15
200
Should the current compliance grace period for
TRID (“good faith effort”) be extended?
6%
94%
Yes
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No
16
Additional TRID Hurdles
What is the added cost of compliance
review/due diligence processes per
transaction?
The average added cost per bank is $300
per transaction, but some banks reported
as high as $1,000 in additional cost.
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What is the average time (in days) lapsed,
from application date to closing date,
under the new TRID regulations?
Under the new TRID regulations, banks
are averaging 8 additional days required
to for the application process, but some
transactions have experienced as many as
20 extra days.
17