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.

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.

Mark Warshal of Fairway Consumer Discount Company, a small mortgage lender, argues that cumulative regulatory requirements—specifically quarterly reporting mandates—impose disproportionate costs on small entities. He urges the Bureau to recognize these burdens and recommend that state regulators reevaluate whether quarterly reporting is necessary or if annual reporting would suffice.

Mark Warshal, Vice-President of Fairway Consumer Discount Company, supports the proposed regulatory changes to promote mortgage credit access and reduce operational burdens. He specifically advocates for eliminating the post-consummation 3-day right of rescission, allowing the cost of second appraisals for property flips to be allocated to other parties, and creating a safe harbor from ATR liability for Qualified Mortgages held in portfolio by small entity creditors.