Comment from RiverStone Lending LLC

Docket ID: CFPB-2026-0081 Agency of CFPB To Whom It May Concern: As a licensed mortgage broker interacting daily with consumers, wholesale lenders, and settlement agents, I appreciate the Bureau’s request for information regarding ways to reduce compliance friction and expand credit access. The operational realities of the current regulatory framework frequently harm the very consumers they are designed to protect, by inflating loan costs, delaying closings, and introducing unnecessary redundancies. I urge the Bureau to consider the following four critical areas for reform: 1. Redundancy of the 3-Day Right of Rescission and Closing Disclosure (CD) Waiting Periods Under current TRID rules, a consumer is already mandated to wait three business days after receiving the Closing Disclosure before they can execute loan documents (consummation). For refinance transactions, the consumer is then forced to wait another three business days under the TILA Right of Rescission before the loan can fund. This back-to-back waiting structure is entirely redundant. The CD waiting period already gives the consumer ample time to review final figures, compare them to the Loan Estimate, and reconsider the transaction before signing. Forcing an additional three-day cooling-off period after signing simply delays funding, increases interest-rate lock extension risks, and causes unnecessary anxiety for borrowers waiting on their funds. Recommendation: Eliminate the post-consummation Right of Rescission for refinance transactions where an independent TRID-compliant Closing Disclosure has already been acknowledged at least three business days prior to closing. 2. The 7-Day Loan Estimate Waiting Period The mandatory 7-business-day waiting period between the delivery of the initial Loan Estimate and the earliest possible consummation date frequently acts as an arbitrary barrier. In straightforward transactions—or in highly efficient digital processing environments—loans are routinely cleared to close before this clock expires. This forces borrowers to wait on an arbitrary calendar rule, rather than moving forward when they are fully prepared and educated on their terms. Recommendation: Transition the 7-day rule to a materiality-based standard, allowing the transaction to proceed to closing earlier if the borrower explicitly consents and final loan terms closely match the initial LE. 3. The Illusion of the "Bona Fide Financial Emergency" Waiver While Regulation Z technically permits consumers to waive both the CD waiting period and the Right of Rescission in the event of a "bona fide financial emergency," this mechanism is entirely broken in practice. Because the Bureau has failed to provide a clear, bright-line definition or a safe-harbor list of "acceptable evidence" for what constitutes an emergency, wholesale lenders universally refuse to accept these waivers. Lenders operate in fear of severe regulatory repercussions or future loan-buyback demands if upon examination later deems the borrower's evidence insufficient. As a result, consumers facing genuine, urgent financial crises are routinely blocked from accessing their capital. Recommendation: Provide explicit, objective criteria and safe-harbor examples of what constitutes a "bona fide financial emergency" so that lenders can confidently honor a consumer's right to waive these periods when facing documented hardship. 4. The Distorting Impact of Zero-Tolerance Regulations The current zero-tolerance framework on specific settlement charges has created a highly counterintuitive market environment. Because there is zero flexibility for errors in these charges, lenders have responded by artificially inflating estimated costs to "cushion" themselves against potential tolerance violations. This systematic inflation means that the initial Loan Estimates provided to consumers can be frequently and highly inaccurate (inflated), artificially driving up the perceived cost of credit and causing unnecessary friction during shopping. Recommendation: Revise the zero-tolerance standard to a reasonable 10% aggregate tolerance for the affected sections. This would give lenders a realistic operational margin, eliminate the practice of cost-cushioning, and ultimately provide consumers with a much more accurate, true-to-life Loan Estimate. Thank you for your time and for considering the perspective of those of us who actually see the daily economic impact of these rules on every American homebuyer and homeowner.