Kristen S. Kautzer, representing Oostburg State Bank, supports the proposed action but advocates for practical reforms to the TRID rule. The Bank argues that current timing and redisclosure requirements create unnecessary costs and delays for both community banks and consumers, and it requests tailored requirements and safe harbors for small institutions.

The commenter, a mortgage broker, supports the proposed three-day "cooling off" period after closing to allow borrowers to review the full closing package. They argue that brokers currently lack visibility into the final documents and that the cooling-off period provides necessary protection for borrowers against errors or undisclosed terms.

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.

A licensed mortgage broker supports the Bureau's request for information on reducing compliance friction and expanding credit access. The commenter argues for specific reforms to eliminate redundant waiting periods, transition to materiality-based standards for loan estimates, clarify "bona fide financial emergency" waivers, and revise zero-tolerance regulations to allow for a reasonable aggregate tolerance.

The commenter argues that the current fee structure for appraisals is deceptive and suppresses appraiser pay while benefiting lenders. They support the CFPB RFI's goal of reworking TRID and fee disclosures to allow for a free market where appraiser fees are clearly separated from Appraisal Management Company (AMC) fees.

Brian Holst, representing Ohnward Bancshares, Inc. (a holding company for three small community banks), argues for several regulatory reliefs to reduce the burden on small institutions. He specifically advocates for eliminating the rescission period for TRID-compliant loans, reclassifying transfer taxes as fees that can increase without a tolerance, and reducing reporting requirements for homeownership counseling, appraisals, and HMDA data.

Wicked Title Forum, an organization providing education and resources for title insurance and settlement professionals, supports targeted reforms to mortgage disclosure requirements. They argue for specific improvements to the TRID rule, such as tailored disclosures for construction loans, clearer title insurance presentations, and standardized electronic data exchanges, while cautioning against wholesale removals of consumer protections.

The commenter, representing a mortgage-related business, argues that current TRID timing requirements and rescission periods cause significant closing delays, increased compliance costs, and higher fees for consumers. They advocate for allowing borrowers to waive these waiting periods, especially in emergencies, and suggest adjusting fee tolerances for items like transfer taxes and appraisals.

Rob Henger, a mortgage banking executive, supports the CFPB's goal of reducing regulatory burden and proposes modernizing TRID and Loan Originator Compensation rules. He argues for replacing transaction-level enforcement with lender performance metrics, updating outdated paper-based timing requirements to electronic acknowledgments, and allowing for more flexible, transparent compensation schedules.

A former residential lender and loan processor argues that the TRID process, specifically the "Changed Circumstances" issues and the three-day waiting periods for Closing Disclosures, creates unnecessary delays and costs for both consumers and banks. The commenter suggests that these regulations slow down the funding process and have not effectively prevented home foreclosures.