Comment from Blue Sky Closing Services, Inc.
Blue Sky Closing Services, Inc.OpposeBusiness
Summary: A title agent with 30 years of experience argues that the TRID rule, specifically the three-day rule and CD balancing, complicates the professional process without providing significant benefits to consumers. The commenter suggests that lenders should only release information once a loan is cleared and advocates for a return to a simpler disclosure process like the HUD.
The three-day rule and CD balancing has been awful. As a title agent for 30 years, I agree that the consumer needs to pay more attention and read their disclosures but the government changing the whole industry in an effort to force their hand has made very little positive changes to the consumer WHILE it complicates the process for the professionals. The lender should be required to disclose three days in advance, a number that cannot deviate more than 10% in either direction. We agree... but by revealing a number, it suggests to the consumer that their loan is cleared to close. The consumer runs on a hampster wheel (usually with their realtor) and does not fully grasp the process, no matter how many times we try to explain it. They don't understand escrow for taxes, even while reviewing an escrow agreement (unless, of course, they are engineers or accountants). The HUD was the most simple, useful, uncomplicated way to manage a closing. The time we spend explaining the TRID RULE, the CD and "final number" vs the three-day number is exhausting in an already exhausting industry. The country is going to lose seasoned title professionals who are mentally drained from consumers who do not pay any attention nor respect our effort to help them understand. Title and lenders are, in a lot of cases, not related and the consumer cannot tell the difference because of the TRID rule. A lender should NOT have to release anything until the loan is cleared, period. Once it's cleared, send instructions to the title company, prepare and review a final HUD that all parties LEARN to understand. Their loan documents, including NOTE details, should be disclosed in advance, yes. Not at closing.