Comment from Anonymous

As a former residential lender from 2014-2019 and as a loan processor for 15 years before that, I saw value in the presentation of a Loan Estimate to an applicant within the three business day timeline, in order to assist the applicant in "shopping" for a mortgage loan. However, I feel that the tolerance buckets and "Changed Circumstances" issues and timelines do not benefit the consumer. Having to be exact on many fees with very little knowledge of them at time of Loan Estimate is extremely hard to forecast. Many times there can be changes to a deal after inspection, appraisal, survey and title work are received. Having to redisclose the LE is not the problem, it is the waiting period. Again most consumers are able to make an informed decision to proceed as soon as they see and sign the disclosure. The time periods for issuing the Closing Disclosure and another 3 day waiting period really slow down a deal, especially with online signing and online closings now. Consumer expect the process to be much faster. In the case of a refinance where the 3 day recission period comes in to play, again the consumer is able to make an informed decision when they are at closing. Many are refinancing for home improvements, debt consolidation etc. The 3 day recission just slows the process of getting funded and is frustrating to the consumer. I really HAVE NOT seen the value in the TRID process as it relates for delinquent loans and foreclosures after the loan has been made. Much of the intent of Dodd-Frank is costly and tedious to the customer, and has not prevented homes from being lost. The Tolerance buckets have also proven to be extremely costly to the banks as well, since we have to refund any costs that go over "tolerance" at closing. Residential lending has not proven to be profitable for many banks in this country, due to the TRID laws.