Should Anyone Touch TRID? The Risk & Roll Panel on the CFPB's Request for Comments
Risk & Roll Podcast · Episode Recap
Six industry groups said, "Don't touch it." The compliance professionals who live inside it every day mostly agree. Here's why.
Earlier this year, Executive Order 14393 directed federal agencies to look at ways to reduce the cost of homebuying. The CFPB responded by opening a request for information on TRID, the TILA-RESPA Integrated Disclosure rule that governs mortgage disclosure timelines. Comments closed recently, and the Risk & Roll panel had a lot to say about whether this is the right problem to be solving, who actually benefits from reform, and what the real friction points in TRID compliance are.
Featured voices: Dana Georgiou (Dunmore) · Bob Simpson (Daylight AML) · Ray Snytsheuvel (Loan Risk Advisors) · Greg Oliven (Polygon Research) · Nathan Knottingham (MLO Force, Host)
🎬 Watch the Full EpisodeCatch the full conversation in the video above.
What TRID Is and Why It's Being Revisited
For anyone outside the industry, TRID is the disclosure framework that sets the timeline for when borrowers receive a loan estimate, how many days before closing they have to receive their closing disclosure, and the minimum time between application and consummation. The three-day windows are the ones that generate the most operational friction, and the rule's 1,800-page preamble is a fairly good indication of how complicated it was to write.
The rule came out of Dodd-Frank and was designed around a simple consumer protection principle: give people time to understand what they're signing before they sign it. The executive order's interest in TRID is framed around homebuying costs, with the premise being that disclosure compliance creates operational burden that gets passed on to borrowers. Six industry groups responded to the RFI with essentially the same position: don't touch it. The panel largely agreed, though not without nuance.
Ray's Perspective: His Law Partner Wrote TRID
Ray Snytsheuvel opened with a disclosure of his own: his law partner Rich Horn was the primary author of TRID. That gave the conversation a dimension most panels can't offer. Ray noted that the rule went through actual consumer focus groups during development, and that many of the criticisms leveled at it today were also leveled at RESPA reform efforts going back to 2002, a process Ray was personally involved in as author of the National Mortgage Bankers Association's comment response.
His core argument: the rule itself is not the problem. The industry has largely figured out TRID. What hasn't been resolved is the weight investors place on even minor errors, turning technical tripwires into unsellable loans and creating enormous operational anxiety around issues that often have no actual impact on the borrower.
"The difference is where I go back to is the weight that people are putting on that error: my God, it's an impossible loan now. And that scares us to death."— Ray Snytsheuvel, Loan Risk Advisors
He also made a point worth holding: TRID is statutory. When you remove regulatory explanation from a statute, the statute still exists. Be careful what you ask for.
Bob's Autopilot Argument
Bob Simpson came at it from a different angle. His experience as an originator dealing directly with the public left him skeptical that most borrowers understand or care about the majority of what TRID discloses. After rate, term, costs, and payment, consumer attention falls off a cliff. Nobody asking their relative at a Labor Day barbecue whether they understand APR is going to get a confident answer.
His argument is that the solution isn't to reform the rule, it's to build better autopilots into loan origination systems. Most of the compliance burden in TRID is manual work that technology should already be handling. If the LOS won't let you close a loan that hasn't cleared every disclosure requirement, the human error problem largely goes away.
"We are manually flying this plane. And I just don't think we should be doing that."— Bob Simpson, Daylight AML
Nathan pointed out that many LOS systems do already have these guardrails built in, which actually makes the timing of a TRID overhaul worse, not better. No LOS vendor wants to retool compliance logic mid-cycle, and the cost of doing so would flow straight back to lenders and ultimately to borrowers.
Where the Real Compliance Pain Is
Ray's conversations with people actively grinding through loans in process pointed to one specific area of genuine friction: change of circumstance documentation. Tracking when a qualifying change of circumstance occurred, documenting it properly, and redisclosing within three days is where files actually get into trouble. That's not a flaw in the rule's structure, it's a training and workflow problem, and it's also the one area that genuinely resists automation because it involves real-world events rather than data points.
His suggestion, floated carefully, was that extending or clarifying the change of circumstance redisclosure window might be the one area where targeted relief could help without unraveling the broader framework.
Dana's Consumer Harm Lens
Dana Georgiou, who operates in the private lending space where TRID doesn't apply and borrowers are repeat sophisticated investors, offered a different frame: the question the industry should be asking is whether there is actual consumer harm.
When a lender misses a tolerance and has to write a check back to a borrower for $200, the borrower typically has no idea why they're receiving it. There's no harm. There may even be a windfall. Designing regulatory reform around those situations doesn't serve the consumer it's supposed to protect.
"When is it really going to be about the consumer? Not for the regulatory people, not for the LOSs, not for all the people that make money off these loans."— Dana Georgiou, Dunmore
She was equally clear that she doesn't think TRID should be touched right now, and that any changes that add to the compliance stack without reducing actual consumer harm are a net negative, especially in a market where costs are already putting pressure on buyers.
Greg's Caution on Moral Hazard
Greg Oliven acknowledged that the RFI process itself is healthy, and that there may be legitimate opportunities for targeted improvements, particularly around overlapping rescission rights. But he flagged a specific risk in what's been floated: loosening the tolerances between the loan estimate and the closing disclosure could create moral hazard by giving lenders more room to quote one thing and deliver another. That's precisely the problem TRID was designed to solve.
He also placed the TRID conversation in its broader context: this is happening inside a supervisory environment where the CFPB has been significantly weakened, where examiner humility pledges are being required before examinations of major lenders, and where deregulatory pressure is coming from multiple directions at once. Tinkering with disclosure rules in that environment carries different risks than it would in a more neutral regulatory climate.
"It's kind of like loosening two legs of the stool. It might start to get a little wobbly."— Greg Oliven, Polygon Research
Key Takeaways
TRID is working. It took years, but the industry has largely figured it out. Revisiting it now resets that clock at significant cost.
The real compliance pain is in change of circumstance documentation, not the core disclosure timeline structure. That's the one area where targeted relief could help.
Investor tripwires, not the rule itself, are driving most of the operational anxiety. Minor technical errors are being treated as fatal flaws. That's an investor behavior problem more than a regulatory one.
Loosening tolerances between the LE and CD could create moral hazard and drive costs up, the opposite of what the executive order intended.
The LOS autopilot argument is the right one. Most of the manual compliance burden in TRID should already be handled by technology.
The consumer harm question is the right frame. If there's no actual harm, reform efforts in that area aren't serving the people they're supposed to protect.
Any changes to TRID happen against a backdrop of significant CFPB weakening. The combination of looser rules and looser enforcement is worth watching carefully.
Risk & Roll covers mortgage compliance, risk, and industry strategy every episode. Subscribe wherever you listen, and leave your feedback in the comments or at support@mloforce.com.
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