OMB Control Number: 3170-0032
TRID Industry Survey for the Closing Company Representative
Introduction
This voluntary survey is being conducted by the Consumer Financial Protection Bureau (CFPB), an agency
of the United States government. The survey will help the CFPB to assess the effectiveness of the CFPB’s
2015 TRID Rule that introduced new requirements for mortgage disclosures.1
Why are you doing this?
This survey will help the CFPB to learn about the experiences of industry participants like you. Your
participation in this survey will help the CFPB to better understand the effects of the TRID Rule, and,
where possible, to create more accurate estimates of these effects.
What happens to my survey responses?
The CFPB will aggregate and anonymize its findings from the survey in an assessment report to be
published on or before October 3, 2020.
IMPORTANT: Please note that this survey will NOT be used, in any way, for supervision or enforcement
purposes.
Who should take this survey?
This survey is intended for REPRESENTATIVES OF INSTITUTIONS THAT CONDUCT CLOSINGS FOR
RESIDENTIAL REAL ESTATE TRANSACTIONS that are secured by mortgage loans covered by the TRID
Rule. For the purpose of this survey, an institution that conducts the closing, or settlement, in a real
estate transaction may include a law firm, a title company, a settlement company, an escrow company,
or any other party providing the service of real estate closing.
We request that your institution submit only one response to this survey. To facilitate completion of this
survey, we suggest that the representative(s) who contribute to this single response have knowledge of
the business practices of your institution, as well as knowledge of your institution’s efforts to comply
with the TRID Rule and the costs of these efforts.
The full name of the rule is the Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act
(Regulation X) and the Truth In Lending Act (Regulation Z) Rule. The rule is also commonly known as the TILARESPA Integrated Disclosure Rule, the Know Before You Owe Rule, TRID, or the TRID Rule.
1
What preparations do I need to take before completing the survey?
The survey will ask questions about your institution, such as your institution’s annual volume of closings.
The survey will also ask questions about your institution’s efforts to comply with the TRID Rule, such as
the amount it spent to implement the TRID Rule.
To determine what resources you will need to complete the survey, you can you preview a printable
version of the complete survey at this link: [provide link].
For a list of definitions of key terms found throughout the survey, please use this link: [provide link].
How long will the survey take to complete?
This survey takes approximately 30-45 minutes to complete.
The survey will save your work so you can stop and continue again whenever you want—just be sure to
remember the log-in information you enter the first time you access the survey.
How long do I have?
There is no time limit on how much time you can spend filling out the survey, we simply ask that you
submit your responses by XXXXX.
Am I required to take this survey?
No. This survey is voluntary.
Are there technology requirements to take the survey?
We recommend using a desktop or laptop computer—the survey is not optimized for mobile phones.
Anything else?
If you have questions, please write to [email protected].
Thank you for your participation.
2
Privacy Act Statement
5 U.S.C. 552(a)(e)(3)
The information you provide through your responses to the Consumer Financial Protection Bureau
(Bureau) will support the Bureau’s assessment of the effectiveness of the TRID Rule. It will not be used
for enforcement or supervision purposes.
The CFPB may collect personally identifiable information (PII) such as your email address.
Information collected by the Bureau will be treated in accordance with the System of Records Notice
(“SORN”), CFPB.022-Market and Consumer Research Records SORN, 77 FR 67802. Although the CFPB
does not anticipate further disclosing the information provided, it may be disclosed as indicated in the
Routine Uses described in the SORN.
This collection of information is authorized by Pub. L. No. 111-203, Title X, Sections 1013 and 1022,
codified at 12 U.S.C. §§ 5493 and 5512.
Your participation is voluntary, and you are not required to participate or share any identifying
information. You may withdraw participation at any time.
3
Paperwork Reduction Act
According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person
is not required to respond to a collection of information unless it displays a valid OMB control number.
The OMB control number for this collection is 3170-0032. It expires on XX/XX/XXXX. Comments
regarding this collection of information, including the estimated response time, suggestions for
improving the usefulness of the information, or suggestions for reducing the burden to respond to this
collection should be submitted to Bureau at the Consumer Financial Protection Bureau (Attention: PRA
Office), 1700 G Street NW, Washington, DC 20552, or by email to [email protected].
4
Additional Information
Certain questions in this survey permit free text responses. In response to these questions, please do
not share any Personally Identifiable Information (PII), including, but not limited to, your name, address,
phone number, email address, Social Security number, etc.
The Bureau will not identify either you or your institution in any reports or other publications that it
issues based on this survey, nor will such reports or publications disclose information in a manner
allowing attribution to specific institutions or individuals. Where you submit information that you both
customarily and actually treat as private, the Bureau intends to treat it as confidential in accordance
with its confidentiality rules at 12 C.F.R. part 1070, including § 1070.20.
5
Login Information
Please enter an email address and an access code (any series of letters or numbers of your choice). If
you must step away from this survey, simply use the same email address and access code the next time
you access the survey and you will start where you previously left off. Email address is required by the
Qualtrics survey platform for this functionality, but will not be linked to your other survey responses by
the CFPB.
Email address:
Access code:
6
Survey Questions
Section 1
Throughout this survey, we define certain terms to make the survey questions clearer. You can see our
definitions by hovering over text that is underlined.
On this page, we define the term “closing” which relies on the definition for “mortgage loans covered by
the TRID Rule.” Please move your mouse over these phrases to see their definitions.
Alternatively, you can find a full list of definitions we use in this survey here:
1. Prior to October 2015, was your institution conducting closings?
Yes
No
If the answer to previous question was “Yes,” continue to next question.
Otherwise, display the following message and then terminate the survey, “Thank you for your
response. This survey focuses on changes in mortgage origination and closing due to the TRID
Rule which came into effect in October 2015, so there is no need for you to complete the survey.”
2. In 2015, approximately how many closings did your institution conduct?
Please use an approximation, if an exact number is not available.
#
3. In 2018, approximately how many closings did your institution conduct?
Please use an approximation, if an exact number is not available.
#
4. In addition to conducting closings, which of the following services does your institution also
currently perform? (check all that apply)
Title Insurance (select one: predominantly buyer paid predominantly seller paid mix
of both buyer and seller paid)
Title search (abstract)
Title examination
Clearing title issues (such as obtaining lien releases)
Escrow (collecting and disbursing consumer payments and loan proceeds)
Legal services
Other, please specify
Free response
7
Section 2
In this section of the survey we are interested in learning about your implementation of the TRID Rule.
We start by asking you about the process of implementation and the use of any temporary compliance
measures. By temporary compliance measures we mean any business solutions that your institution
used to comply with the TRID Rule that it likely would not have used as a long-term solution had it had
more time to develop a compliance plan.
5. Did your institution use temporary compliance measures to comply with the TRID Rule by
the effective date?
Yes
No
6. If yes, why did your institution use temporary compliance measures to comply with the TRID
Rule by the effective date?
Free response
8
7. Regarding each of the following topics, when did your institution complete its long-term
solution for TRID implementation so that it no longer relied on temporary compliance
measures, if any were used?
Before
October 3,
2015
By December
3, 2015
By October
3, 2016
After
October 3,
2016
Not
Applicable
Updating or creating
compliance tools, such as
templates, job aids, and
recorded trainings
d) Reviewing relationships and
renegotiating contracts, where
applicable
Updating or creating
information technology
systems (including internal
and consumer-facing systems)
Overall implementation
a)
Understanding the
requirements of TRID and
updating or creating relevant
policies and procedures
(consider all major Rulerelated updates and creations,
but not minor regular updates)
b) Initial training of sales and
operations staff to come into
compliance with the Rule
c)
e)
f)
8. How challenging were the following interactions during TRID implementation?
a)
Coordinating with mortgage loan
originators
b) Coordinating with third parties (e.g.
software vendors)
c) Receiving guidance from CFPB
Not
challenging
Somewhat
challenging
Very
challenging
Not
Applicable
9. How helpful were the following tools during TRID implementation?
Somewhat
Helpful
Not Helpful
9
Very Helpful
I did not attempt to use
this tool
Non-government resources
a)
Trade groups or other industry
sources
b) Title insurance underwriters
c)
Software vendors
Government resources
d) CFPB websites for real estate and
settlement professionals
e)
CFPB’s Small Entity compliance
guide or Guide to forms
f)
Option to submit question to
CFPB’s Regulations Inquiries
email box
10
Next, we are interested in the costs to your institution of implementing the TRID Rule. Generally,
implementation costs were additional one-time costs, beyond business as usual, that your institution
incurred in order to come into compliance with the TRID Rule. In your estimates of implementation
costs, please do not include:
• costs due to business as usual
• costs that your institution incurs on an ongoing basis in order to stay in compliance with the
TRID Rule (e.g. increased cost of closing attributable to the TRID Rule); or
• costs you would have incurred if the TRID Rule was never implemented
For example, if you conducted employee training when implementing the TRID Rule…
• If you would have conducted that training or similar training anyway, even without the TRID
Rule, then the cost of this training attributable to the TRID Rule would be $0.
• If instead, without the TRID Rule, you would not have conducted this training, then cost of
the training would be a cost due to the TRID Rule.
10. Approximately what were the total costs of implementing the TRID Rule due to each of the
following factors?
Please include both personnel and non-personnel costs and the cost of contracting with third
parties such as software vendors or outside counsel. Please use approximations if exact cost
figures are not available.
Total dollar cost
a)
Understanding the requirements of TRID and updating or creating
relevant policies and procedures (consider all major Rule-related
updates and creations, but not minor regular updates)
_$
b) Initial training of sales and operations staff to come into compliance
with the Rule
_$
c)
Updating or creating compliance tools, such as templates, job aids,
and recorded trainings
d) Reviewing relationships and renegotiating contracts, where
applicable
e)
f)
Updating or creating information technology systems (including
internal and consumer-facing systems)
Other: please specify
_$
_$
_$
_$
11. Summing your responses to the previous question, your institution spent $XYZ
implementing the TRID Rule, or <$XYZ/#2015 originations> per closing in 2015. Is this
approximately correct?
Yes
No. To implement the TRID Rule, my institution spent approximately $
$ per closing in 2015.
11
or
Section 3
In this section of the survey we ask about the ongoing costs of compliance with the TRID Rule.
12. Approximately what was your institution’s average cost of providing settlement services for
a closing during the three time periods below?
Please include both personnel and non-personnel costs. Please use approximations if exact cost
figures are not available.
Timeframe
Cost per closing
a)
October 2014 through October 2, 2015 (year before the
TRID Rule took effect)
b) October 3, 2015 through October 2016 (first year after
the TRID Rule took effect)
c) Calendar year 2018
$
$
$
13. Approximately what was your institution’s average revenue from providing settlement
services for a closing during the three time periods below?
Please use approximations if exact cost figures are not available.
Timeframe
Revenue per closing
a)
October 2014 through October 2, 2015 (year before the
TRID Rule took effect)
b) October 3, 2015 through October 2016 (first year after the
TRID Rule took effect)
c)
Calendar year 2018
$
$
$
12
14. Comparing calendar year 2018 to the year before the TRID Rule took effect, approximately
how much did each of the following factors contribute to any change in your institution’s
cost of providing settlement services for a closing?
Change in time spent coordinating
with mortgage loan originators
Change in time spent coordinating
with third parties
Change in number of revised
disclosures, if any
Change in time spent on ongoing
training, if any
Change in timing of closings, if
any delayed closings
Change in need for legal advice
Other: Please Specify
N/A
(My institution
did not
experience a
change in this
factor)
Increased
costs
significantly
Increased
costs
somewhat
Neither
increased
nor
decreased
costs
Decreased
costs
somewhat
Decreased
costs
significantly
13
Section 4
This section is focused on the experiences and outcomes of consumers who used your institution’s
settlement services during a closing. Please answer the following questions, and complete the following
sentences, when applicable, with the responses that best fit your experience.
15. In the year before the TRID Rule took effect, on average how many days before settlement
was a HUD-1 settlement statement provided to the consumer?
This question is asking about the first time the HUD-1 settlement statement was given to the
consumer. This is distinct from the first time the HUD-1 settlement statement was made
available, as a disclosure can be made available without a consumer actually obtaining it.
On the same day
One business day before
Two business days before
Three or more business days before
I don’t know
16. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of consumers who inquired about, but then did not use, your institution’s
settlement services change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
17. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of consumers who presented cost estimates from another settlement agent or
institution change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
14
18. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of consumers who negotiated prices for your settlement services change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
15
Section 5
This section is focused on the types and costs of settlement services consumers get from your
institution. In answering, please consider the loans that your institution closed before and after TRID
implementation.
In this section, we will often ask about “settlement services.” By settlement services, we are referring to
the services you listed in responding to Question 4. We also ask about “costs”. For settlement services
whose price does not vary with loan or transaction size, for example notarization, please interpret “cost”
to mean dollar cost. For settlement services that increase in price with loan or transaction size, for
example title insurance premiums, please interpret “cost” to mean rate.
19. Comparing calendar year 2018 to the year before the TRID Rule took effect, how has the
percentage of consumers who purchased an Owner’s Title Insurance Policy changed?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
20. Comparing calendar year 2018 to the year before the TRID Rule took effect, how have Owner’s
Title Insurance Policy premiums changed?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
21. Comparing calendar year 2018 to the year before the TRID Rule took effect, on average, how
did the total number of settlement services provided by your institution per closing (that is,
how many services you provided per closing) change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
16
Decreased significantly
I don’t know
22. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, on average, how did the total cost to consumers of settlement services provided by
your institution per closing change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
23. Comparing calendar year 2018 to the year before the TRID Rule took effect, on average, how
did the total cost to consumers of settlement services provided by your institution per closing
change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
24. Comparing calendar year 2018 to the year before the TRID Rule took effect, please list up to
three settlement services that, on average, increased in cost most substantially.
Settlement Service
1.
2.
3.
25. Comparing calendar year 2018 to the year before the TRID Rule took effect, please list up to
three settlement services that, on average, decreased in cost most substantially.
17
Settlement Service
1.
2.
3.
26. Comparing calendar year 2018 to the year before the TRID Rule took effect, please list up to
three settlement services that, on average, neither increased nor decreased in cost
substantially.
Settlement Service
1.
2.
3.
Thank you for taking the survey. We appreciate the time you devoted to making this a more
informed assessment. If you have any additional comments, please use this space to describe
effects of the TRID Rule that you think the survey may have otherwise missed.
18
OMB Control Number: 3170-0032
TRID Industry Survey for Mortgage Loan Officers
Introduction
This voluntary survey is being conducted by the Consumer Financial Protection Bureau (CFPB), an agency
of the United States government. The survey will help the CFPB to assess the effectiveness of the CFPB’s
2015 TRID Rule that, among other things, introduced new requirements for mortgage disclosures.1
Why are you doing this?
This survey will help the CFPB learn about the experiences of industry participants like you. Your
participation in this survey will help the CFPB to better understand the effects of the TRID Rule, and,
where possible, to create more accurate estimates of these effects.
What happens to my survey responses?
The CFPB will aggregate and anonymize its findings from the survey in an assessment report to be
published on or before October 3, 2020.
IMPORTANT: Please note that this survey will NOT be used, in any way, for supervision or enforcement
purposes.
Who should take this survey?
This version of the survey is intended for MORTGAGE LOAN OFFICERS who provide residential mortgage
loans that are covered by the TRID Rule. For the purpose of this survey, a mortgage loan officer is the
natural person employed by a creditor or mortgage broker who interacts most frequently with the
consumer and who has an NMLSR ID. Loan officers therefore include most individuals who originate or
broker mortgage loans.
The full name of the rule is the Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act
(Regulation X) and the Truth In Lending Act (Regulation Z) Rule. The rule is also commonly known as the TILARESPA Integrated Disclosure Rule, the Know Before You Owe Rule, TRID, or the TRID Rule
1
What preparations do I need to take before completing the survey?
The survey will ask some questions about your institution, such as total annual loan volumes, and so you
may need to seek assistance in answering these questions. However, most questions in this survey are
about your own personal experience, and you should therefore be able to complete most questions
without assistance.
To determine what resources you will need to complete the survey, you can you preview a printable
version of the complete survey at this link: [provide link].
For a list of definitions of key terms found throughout the survey, use this link: [provide link].
How long will the survey take to complete?
This survey takes approximately 20-30 minutes to complete.
The survey will save your work so you can stop and continue again whenever you want—just be sure to
remember the log-in information you enter the first time you access the survey.
How long do I have?
There is no time limit on how much time you can spend filling out the survey, we simply ask that you
submit your responses by XXXXX.
Am I required to take this survey?
No. This survey is voluntary.
Are there technology requirements to take the survey?
We recommend using a desktop or laptop computer—the survey is not optimized for mobile phones.
Anything else?
If you have questions, please write to [email protected].
Thank you for your participation.
2
Privacy Act Statement
5 U.S.C. 552(a)(e)(3)
The information you provide through your responses to the Consumer Financial Protection Bureau
(Bureau) will support the Bureau’s assessment of the effectiveness of the TRID Rule. It will not be used
for enforcement or supervision purposes.
The CFPB may collect personally identifiable information (PII) such as your email address.
Information collected by the Bureau will be treated in accordance with the System of Records Notice
(“SORN”), CFPB.022-Market and Consumer Research Records SORN, 77 FR 67802. Although the CFPB
does not anticipate further disclosing the information provided, it may be disclosed as indicated in the
Routine Uses described in the SORN.
This collection of information is authorized by Pub. L. No. 111-203, Title X, Sections 1013 and 1022,
codified at 12 U.S.C. §§ 5493 and 5512.
Your participation is voluntary, and you are not required to participate or share any identifying
information. You may withdraw participation at any time.
3
Paperwork Reduction Act
According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person
is not required to respond to a collection of information unless it displays a valid OMB control number.
The OMB control number for this collection is 3170-0032. It expires on XX/XX/XXXX. Comments
regarding this collection of information, including the estimated response time, suggestions for
improving the usefulness of the information, or suggestions for reducing the burden to respond to this
collection should be submitted to Bureau at the Consumer Financial Protection Bureau (Attention: PRA
Office), 1700 G Street NW, Washington, DC 20552, or by email to [email protected].
4
Additional Information
Certain questions in this survey permit free text responses. In response to these questions, please do
not share any Personally Identifiable Information (PII), including, but not limited to, your name, address,
phone number, email address, Social Security number, etc.
The Bureau will not identify either you or your institution in any reports or other publications that it
issues based on this study, nor will such reports or publications disclose information in a manner
allowing attribution to specific institutions or individuals. Where you submit information that you both
customarily and actually treat as private, the Bureau intends to treat it as confidential in accordance
with its confidentiality rules at 12 C.F.R. part 1070, including § 1070.20.
5
Login Information
Please enter an email address and an access code (any series of letters or numbers of your choice). If
you must step away from this survey, simply use the same email address and access code the next time
you access the survey and you will start where you previously left off. Email address is required by the
Qualtrics survey platform for this functionality, but will not be linked to your other survey responses by
the CFPB.
Email address:
Access code:
6
Data Quality
We ask for each respondent’s institution NMLSR ID so that we may account for the fact that different
numbers of Loan Officers may respond from each institution. This accounting will ultimately improve the
quality of the assessment’s estimates of the effects of the TRID Rule.
As stated above, we will not disclose information in a manner allowing attribution to you or your
institution, and this survey will not be used for enforcement or supervision purposes.
Please provide the following information about your institution.
Company NMLSR ID:
7
Survey Questions
Section 1
Throughout this survey, we define certain terms to make the survey questions clearer. You can see our
definitions by hovering over text that is underlined.
On this page, we define the terms “mortgage loan officer” and “mortgage loans covered by the TRID
Rule.” Please move your mouse over these phrases to see their definitions.
Alternatively, you can find a full list of definitions we use in this survey here:
1. Did you act as a mortgage loan officer for mortgage loans that would be covered by the
TRID Rule prior to October 2015?
Yes, I was originating mortgage loans
Yes, I was brokering mortgage loans
No
If No, display the following message and then terminate the survey, “Thank you for your response. This
survey focuses on changes in mortgage origination and closing due to the TRID Rule which came into
effect in October 2015, so there is no need for you to complete the survey.”
If mortgage broker, skip to question 4.
2. Which of the following options best describes the institution you work for? Choose one.
A bank
A credit union
A non-depository mortgage lender (informally referred to as non-bank) – an affiliate of a bank or a credit
union
A non-depository mortgage lender (informally referred to as non-bank) – not an affiliate of a bank or a
credit union—please specify:
If non-depository, skip to question 4.
3. Approximately what was the value of your institution’s assets at the end of 2018?
Less than $50 million
$50 million to $100 million
$100 million to $550 million
$550 million to $1 billion
8
$1 billion to $2 billion
$2 billion to $10 billion
More than $10 billion
The following questions ask about the quantity of mortgage loans covered by the TRID Rule that your
institution originated or brokered in different years. In your responses, please only include retail and
consumer direct loans. Do not include correspondent loans.
4. In calendar year 2018, approximately how many mortgage loans covered by the TRID Rule
did your institution originate or broker?
#
5. In calendar year 2018, approximately what was the total dollar amount of mortgage loans
covered by the TRID Rule your institution originated or brokered?
$
9
Section 2
Please answer the following questions, and complete the following sentences, when applicable, with the
responses that best fit your personal experience.
6. In calendar year 2018, in addition to giving consumers who applied for a mortgage loan a
Loan Estimate (LE), to approximately what percentage did you give non-binding
documents that describe loan terms and closing costs (sometimes known as “worksheets”)?
%
7. In the year before the TRID Rule took effect, on average how many days after first contact
between you and a consumer was a Good Faith Estimate (GFE) sent to the consumer?
Days
8. In calendar year 2018, on average how many days after first contact between you and a
consumer was a Loan Estimate sent to the consumer?
Days
9. In calendar year 2018, after the initial Loan Estimate was provided to a consumer,
approximately how many revised Loan Estimates did you issue (often called reissue) per
consumer?
Less than one per consumer
Between one and two
Between two and three
More than three
I don’t know
10. How does the number of revised GFEs issued per consumer in the year before the TRID
Rule took effect compare to the number of revised Loan Estimates (LE) issued per
consumer in calendar year 2018.
The number of revised LEs is significantly greater
The number of revised LEs is somewhat greater
The number of revised LEs is about the same
The number of revised LEs is somewhat smaller
The number of revised LEs is significantly smaller
10
I don’t know
11. In calendar year 2018, after the initial Closing Disclosure was provided to the consumer,
approximately how many revised Closing Disclosures did you issue per consumer?
Less than one per consumer
Between one and two
Between two and three
More than three
I don’t know
12. In calendar year 2018, on average, how many days before consummation was a final Closing
Disclosure (i.e. one that was not subsequently revised) first sent to the consumer?
On the same day
One business day before
Two business days before
Three or more business days before
I don’t know
13. Considering only the initial disclosure (that is, not any revised disclosures), which do you
think had more accurate estimates of the final loan terms and closing costs of a mortgage
loan?
Initial Loan Estimates typically had more accurate estimates of final loan terms and closing costs
than initial GFEs
Neither initial Loan Estimates nor initial GFEs was notably better than the other in terms of
accuracy of estimates
Initial GFEs typically had more accurate estimates of final loan terms and closing costs than initial
Loan Estimates
14. How often do you think the initial Closing Disclosure (that is, not considering any revised
disclosures) is an accurate representation of final loan terms and closing costs of a mortgage
loan?
Almost always
Often
Sometimes
11
Rarely
Never
12
Section 3
This section is focused on the experiences and outcomes of applicants and borrowers
15. On average, how did the number of questions consumers asked you about their Loan
Estimate in calendar year 2018 compare to the number of questions they asked you about
their GFE or initial TIL disclosure in the year before the TRID Rule took effect?
Significantly more
Somewhat more
About the same
Somewhat fewer
Significantly fewer
I don’t know
16. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of consumers who presented loan terms from another lender using an initial
disclosure change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
17. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of consumers who negotiated with you on loan terms change?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
13
18. In calendar year 2018, of the consumers who presented loan term estimates from another
lender, how did they present this information?
Almost Always
Often
Sometimes
Rarely
Never
d) Using advertisements
e)
Using comparison websites
or other aggregators
f)
Other
a)
Using Loan Estimates
b) Using lender-issued nonbinding documents that
describe loan terms and
closing costs (sometimes
known as “worksheets”)
c)
Using quotes they received
orally from other lenders
19. Considering only initial disclosure (that is, not any revised disclosures), which do you think
is more confusing for consumers?
LE was less confusing than the GFE and Initial TIL
LE was the same relative to the GFE and Initial TIL in terms of consumer confusion
LE was more confusing than the GFE and Initial TIL
20. Considering only initial disclosure (that is, not any revised disclosures), which do you think
is more confusing for consumers?
CD was less confusing than the HUD-1 and Final TIL
CD was the same relative to the HUD-1 and Final TIL in terms of consumer confusion
CD was more confusing than the HUD-1 and Final TIL
14
Section 4
21. Comparing calendar year 2018 to the year before the TRID Rule took effect, thinking only
of settlement services for which you allow consumers to shop, how has the percentage of
consumers who choose a provider not on the written list of service providers changed?
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
Thank you for taking the survey. We appreciate the time you devoted to making this a more informed
assessment. If you have any additional comments, please use this space to describe effects of the TRID
Rule that you think the survey may have otherwise missed.
15
OMB Control Number: 3170-0032
TRID Industry Survey for Mortgage Lenders
Introduction
This voluntary survey is being conducted by the Consumer Financial Protection Bureau (CFPB), an agency
of the United States government. The survey will help the CFPB to assess the effectiveness of the CFPB’s
2015 TRID Rule that, among other things, introduced new requirements for mortgage disclosures.1
Why are you doing this?
This survey will help the CFPB to learn about the experiences of industry participants like you. Your
participation in this survey will help the CFPB to better understand the effects of the TRID Rule, and,
where possible, to create more accurate estimates of these effects.
What happens to my survey responses?
The CFPB will aggregate and anonymize its findings from the survey in an assessment report to be
published on or before October 3, 2020.
IMPORTANT: Please note that this survey will NOT be used, in any way, for supervision or enforcement
purposes.
Who should take this survey?
This survey is intended for REPRESENTATIVES OF MORTGAGE LOAN ORIGINATION INSTITUTIONS that
provide residential mortgages covered by the TRID Rule. For the purpose of this survey, a mortgage loan
origination institution is any institution that originates loans directly to consumers (generally referred to
as retail and/or consumer direct lender). This includes, for example, banks and credit unions, as well as
non-depository institutions. If your institution originates different types of mortgage loans through
multiple channels, please focus on your mortgage origination activity in the retail/consumer direct
channel for residential mortgages covered under the TRID Rule.
We request that your institution submit only one response to this survey. To facilitate completion of this
survey, we suggest that the representative(s) who contribute to this single response have knowledge of
The full name of the rule is the Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act
(Regulation X) and the Truth In Lending Act (Regulation Z) Rule. The rule is also commonly known as the TILARESPA Integrated Disclosure Rule, the Know Before You Owe Rule, TRID, or the TRID Rule
1
the business practices of your institution, as well as knowledge of your institution’s efforts to comply
with the TRID Rule and the costs of these efforts.
What preparations do I need to take before completing the survey?
The survey will ask questions about your institution, such as your institution’s annual volume of
mortgage loans covered by the TRID Rule. The survey will also ask questions about your institution’s
efforts to comply with the TRID Rule, such as the amount it spent to implement the TRID Rule.
To determine what resources you will need to complete the survey, you can you preview a printable
version of the complete survey at this link: [provide link].
For a list of definitions of key terms found throughout the survey, use this link: [provide link].
How long will the survey take to complete?
This survey takes approximately 60-75 minutes to complete.
The survey will save your work so you can stop and continue again whenever you want—just be sure to
remember the log-in information you enter the first time you access the survey.
How long do I have?
There is no time limit on how much time you can spend filling out the survey, we simply ask that you
submit your responses by XXXXX.
Am I required to take this survey?
No. This survey is voluntary.
Are there technology requirements?
We recommend using a desktop or laptop computer—the survey is not optimized for mobile phones.
Anything else?
If you have questions, please write to [email protected].
2
Thank you for your participation.
3
Privacy Act Statement
5 U.S.C. 552(a)(e)(3)
The information you provide through your responses to the Consumer Financial Protection Bureau
(Bureau) will support the Bureau’s assessment of the effectiveness of the TRID Rule. It will not be used
for enforcement or supervision purposes.
The CFPB may collect personally identifiable information (PII) such as your email address.
Information collected by the Bureau will be treated in accordance with the System of Records Notice
(“SORN”), CFPB.022-Market and Consumer Research Records SORN, 77 FR 67802. Although the CFPB
does not anticipate further disclosing the information provided, it may be disclosed as indicated in the
Routine Uses described in the SORN.
This collection of information is authorized by Pub. L. No. 111-203, Title X, Sections 1013 and 1022,
codified at 12 U.S.C. §§ 5493 and 5512.
Your participation is voluntary, and you are not required to participate or share any identifying
information. You may withdraw participation at any time.
4
Paperwork Reduction Act
According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person
is not required to respond to a collection of information unless it displays a valid OMB control number.
The OMB control number for this collection is 3170-0032. It expires on XX/XX/XXXX. Comments
regarding this collection of information, including the estimated response time, suggestions for
improving the usefulness of the information, or suggestions for reducing the burden to respond to this
collection should be submitted to Bureau at the Consumer Financial Protection Bureau (Attention: PRA
Office), 1700 G Street NW, Washington, DC 20552, or by email to [email protected].
5
Additional Information
Certain questions in this survey permit free text responses. In response to these questions, please do
not share any Personally Identifiable Information (PII), including, but not limited to, your name, address,
phone number, email address, Social Security number, etc.
The Bureau will not identify either you or your institution in any reports or other publications that it
issues based on this survey, nor will such reports or publications disclose information in a manner
allowing attribution to specific institutions or individuals. Where you submit information that you both
customarily and actually treat as private, the Bureau intends to treat it as confidential in accordance
with its confidentiality rules at 12 C.F.R. part 1070, including § 1070.20.
6
Login Information
Please enter an email address and an access code (any series of letters or numbers of your choice). If
you must step away from this survey, simply use the same email address and access code the next time
you access the survey and you will start where you previously left off. Email address is required by the
Qualtrics survey platform for this functionality, but will not be linked to your other survey responses by
the CFPB.
Email address:
Access code:
7
Survey Questions
Section 1
1. Which of the following options best describes your institution? Choose one.
A bank
A credit union
A non-depository mortgage lender (informally referred to as non-bank) – an affiliate of a bank or a
credit union
A non-depository mortgage lender (informally referred to as non-bank) – not an affiliate of a bank
or a credit union—please specify:
If non-depository, skip to question 3.
2. Approximately what was the value of your institution’s assets at the end of 2018?
Less than $50 million
$50 million to $100 million
$100 million to $550 million
$550 million to $1 billion
$1 billion to $2 billion
$2 billion to $10 billion
More than $10 billion
Throughout this survey, we define certain terms to make the survey questions clearer. You can see our
definitions by hovering over text that is underlined.
On this page, we define the term “mortgage loans covered by the TRID Rule.” Please move your mouse
over this phrase to see its definition.
Alternatively, you can find a full list of definitions we use in this survey here:
3. Was your institution originating mortgage loans that would be covered by the TRID Rule
prior to October 2015?
Yes
8
No
If the answer to previous question was “Yes,” continue to next question.
Otherwise, display the following message and then terminate the survey, “Thank you for your
response. This survey focuses on changes in mortgage origination and closing due to the TRID
Rule which came into effect in October 2015, so there is no need for you to complete the survey.”
The following questions ask about the number of mortgage loans that would be covered by the TRID
Rule that your institution originated in 2015. In your responses, please only include retail and consumer
direct loans. Do not include correspondent loans.
4. In calendar year 2015, approximately how many mortgage loans that would be covered by the
TRID Rule did your institution originate?
#
5. In calendar year 2015, of the mortgage loans that would be covered by the TRID Rule that
your institution originated, approximately what percentage were each of the following?
a) Purchase first mortgage
%
b) Purchase second mortgage
%
c) Refinance mortgage
%
6. In calendar year 2015, of the mortgage loans that would be covered by the TRID Rule that
your institution originated, approximately what percentage were each of the following?
a) Conventional, conforming
%
b) Government Loans (non-conventional)
%
c) Conventional, non-conforming
%
The following questions ask about the number of mortgage loans covered by the TRID Rule that your
institution originated in 2018. In your responses, please only include retail and consumer direct loans. Do
not include correspondent loans.
9
7. In calendar year 2018, approximately how many mortgage loans covered by the TRID Rule
did your institution originate?
#
8. In calendar year 2018, approximately what was the total dollar amount of mortgage loans
covered by the TRID Rule your institution originated?
$
10
Section 2
This section asks about your institution’s implementation of the TRID Rule. In answering these
questions, please consider the TRID Rule as of the effective date, October 3, 2015. Please do not
consider amendments the Bureau made to the TRID Rule after that time or other regulations such as the
Ability to Repay/Qualified Mortgage or Mortgage Servicing Rules.
9. What kind of loan origination system (LOS) did your institution use during each of the
following time periods?
Please choose one option per time period (column). If you used multiple systems, please choose
the system used for the largest number of loans.
October 2014 through
October 2, 2015
October 3, 2015
through October 2016
(year before the TRID
Rule took effect)
(first year after the
TRID Rule took effect)
d) Standard system developed by a thirdparty vendor and provided on demand
(e.g., in the cloud)
e)
Manual preparation
f)
Something else
a)
System developed in-house
b) Custom in-house system developed by a
third-party vendor
c)
Standard system developed by a thirdparty vendor and installed on our premises
g) Do not know
10. If applicable, did you change third-party LOS vendors around the time the TRID Rule took
effect?
Yes, we changed third-party LOS vendors
No, we worked with the same third-party LOS vendor
11
Calendar
Year 2018
Do not know
We next would like to know if you used any temporary compliance measures during the process of
implementation. By temporary compliance measures we mean any business solutions that your
institution used to comply with the TRID Rule that it likely would not have used as a long-term solution
had it had more time to develop a compliance plan.
11. Did your institution use temporary compliance measures to comply with the TRID Rule by
the effective date?
Yes
No
12. If yes, why did your institution use temporary compliance measures to comply with the
TRID Rule by the effective date?
Free response
12
13. Regarding each of the following topics, when did your institution complete its long-term
solution for TRID implementation so that it no longer relied on temporary compliance
measures, if any were used?
Before
October 3,
2015
By December
3, 2015
By October
3, 2016
After
October 3,
2016
Not
Applicable
Updating or creating
compliance tools, such as
templates, job aids, and
recorded trainings
d) Reviewing relationships and
renegotiating contracts, where
applicable, with mortgage
brokers, closing agents, and
title companies
Updating or creating loan
origination systems and
related information
technology systems
Overall implementation
a)
Understanding the
requirements of TRID and
updating or creating relevant
policies and procedures
(consider all major Rulerelated updates and creations,
but not minor regular updates)
b) Initial training of sales and
operations staff to come into
compliance with the Rule
c)
e)
f)
14. How challenging were the following interactions during TRID implementation?
a)
Coordinating with software vendors
13
Not
challenging
Somewhat
challenging
Very
challenging
Not
Applicable
b) Coordinating with settlement agents
c)
Receiving guidance from CFPB
d) Coordinating with brokers or
correspondent entities
15. How helpful were the following tools during TRID implementation?
Not Helpful
Somewhat
Helpful
Very Helpful
I did not attempt to use
this tool
d) Option to submit question to
CFPB’s Regulations Inquiries
email box
e)
CFPB Examination Procedures
f)
CFPB websites for real estate and
settlement professionals
g) Non-government resources (e.g.,
trade group or other industry
websites) – can list as appropriate
by adding rows to digital survey
a)
CFPB’s Small Entity compliance
guide
b) CFPB’s Guide to forms
c)
Federal Reserve Board Outlook
Live Webinars
14
Section 3
In this section, we are interested in the costs to your institution of implementing the TRID Rule.
Generally, implementation costs were additional one-time costs, beyond business as usual, that your
institution incurred in order to come into compliance with the TRID Rule. In your estimates of
implementation costs, please do not include:
•
•
•
costs due to business as usual
costs that your institution incurs on an ongoing basis in order to stay in compliance with the
TRID Rule (e.g. increased cost of mortgage origination attributable to the TRID Rule); or
costs you would have incurred if the TRID Rule was never implemented
For example, if you conducted employee training when implementing the TRID Rule…
•
•
If you would have conducted that training or similar training anyway, even without the TRID
Rule, then the cost of this training attributable to the TRID Rule would be $0.
If instead, without the TRID Rule, you would not have conducted this training, then the cost
of the training would be a cost due to the TRID Rule.
16. Approximately what were the total costs of implementing the TRID Rule due to each of the
following factors?
Please include both personnel and non-personnel costs and the cost of contracting with third
parties such as software vendors or outside counsel. Please use approximations if exact cost
figures are not available.
Total dollar cost
a)
Understanding the requirements of TRID and updating or creating
relevant policies and procedures (consider all major Rule-related
updates and creations, but not minor regular updates)
b) Initial training of sales and operations staff to come into compliance
with the Rule
_$
_$
c)
Updating or creating compliance tools, such as templates, job aids,
and recorded trainings
_$
d)
Reviewing relationships and renegotiating contracts, where
applicable, with mortgage brokers, closing agents, and title companies
_$
e)
Updating or creating loan origination systems and related information
technology systems
_$
f)
Other: please specify
_$
15
17. Summing your responses to the previous question, your institution spent $XYZ
implementing the TRID Rule, or <$XYZ/#2015 originations> per mortgage loan that would
be covered by the TRID Rule originated in 2015. Is this approximately correct?
Yes
No. To implement the TRID Rule, my institution spent approximately $
or
$ per mortgage loan that would be covered by the TRID Rule
originated in 2015.
16
Section 4
In this section we ask about your institution’s ongoing costs, generally. In answering these questions:
•
•
•
Please do not include implementation costs in your estimates.
When considering mortgage loan origination, please only consider mortgage loans that are
covered by the TRID Rule.
When considering loan origination, please only include retail and consumer direct loans. Do
not include correspondent loans.
17. Approximately what was your institution’s production cost per mortgage loan covered by
the TRID Rule (that is, your institution’s total loan production costs, divided by the number of
loans originated) during the three time periods below?
Timeframe
a)
Cost per loan
October 2014 through October 2, 2015 (year before the
TRID Rule took effect)
$
b) October 3, 2015 through October 2016 (first year after
the TRID Rule took effect)
$
c)
$
Calendar year 2018
18. Approximately what was your institution’s revenue per mortgage loan covered by the TRID
Rule (that is, your institution’s total loan production revenues, divided by the number of loans
originated) during the three time periods below?
Revenue per
loan
Timeframe
a)
October 2014 through October 2, 2015 (year before the
TRID Rule took effect)
$
b) October 3, 2015 through October 2016 (first year after
the TRID Rule took effect)
$
c)
$
Calendar year 2018
21. Comparing calendar year 2018 to the year before the TRID Rule took effect, approximately
how much did each of the following factors contribute to any change in your institution’s
cost per mortgage loan origination?
17
N/A
(My institution
did not
experience a
change in this
factor)
Increased
costs
significantly
Increased
costs
somewhat
Change in process for estimating
or verifying closing costs, if any
Change in frequency of absorbing
or refunding consumers for costs
or fees that rise above tolerances,
if any
Change in efficiency of loan
origination process, if any
Change in ease of disclosure
provision, if any
Change in requirements or
process for developing compliant
disclosure for unusual mortgage
loans, if any
Change in number of initial
disclosures (not including revised
disclosures) issued (Loan
Estimates, Good Faith
Estimates/Initial TIL
Disclosures), if any
Change in number of revised
disclosures, if any
Change in need for ongoing
training, if any
Change in need for coordination
with third parties, if any
Change in timing of closings, if
any
Change in pre-closing quality
control, if any
Change in post-closing audit and
verification, if any
Change in number of questions
from consumers, if any
Change in need for legal advice,
if any
Other: Please Specify
Neither
increased
nor
decreased
costs
Decreased
costs
somewhat
Decreased
costs
significantly
18
22. Thinking back to the year before the TRID Rule took effect, in order to avoid tolerance
violations on settlement service fees, how often did your institution do each of the following
on a mortgage loan?
a)
For a fee that can vary, in good
faith, across a range, disclosed
an estimated fee amount that was
at the top of that range
b) When allowing consumers to
shop, provided the consumer
with a written list of service
providers with only one provider
c)
Where permitted, required the
use of a specific settlement
service provider (moving the fee
to the 0% tolerance category)
d) Entered into contracts or
agreements with settlement
providers to limit rate fluctuation
e)
Absorbed or refunded consumers
for costs or fees that rose above
tolerances
Almost
Always
Often
Sometimes
Rarely
Never
23. Thinking back to the year after the TRID Rule took effect, in order to avoid tolerance
violations on settlement service fees, how often did your institution do each of the following
on a mortgage loan?
a)
For a fee that can vary, in good
faith, across a range, disclosed
an estimated fee amount that was
at the top of that range
b) When allowing consumers to
shop, provided the consumer
with a written list of service
providers with only one provider
Almost
Always
Often
Sometimes
Rarely
Never
19
c)
Where permitted, required the
use of a specific settlement
service provider (moving the fee
to the 0% tolerance category)
d) Entered into contracts or
agreements with settlement
providers to limit rate fluctuation
e)
Absorbed or refunded consumers
for costs or fees that rose above
tolerances
24. Thinking back to calendar year 2018, in order to avoid tolerance violations on settlement
service fees, how often did your institution do each of the following on a mortgage loan?
a)
For a fee that can vary, in good
faith, across a range, disclosed
an estimated fee amount that was
at the top of that range
b) When allowing consumers to
shop, provided the consumer
with a written list of service
providers with only one provider
c)
Where permitted, required the
use of a specific settlement
service provider (moving the fee
to the 0% tolerance category)
d) Entered into contracts or
agreements with settlement
providers to limit rate fluctuation
e)
Absorbed or refunded consumers
for costs or fees that rose above
tolerances
Almost
Always
Often
Sometimes
Rarely
Never
20
Section 5
In this section of the survey we ask questions about the time it took to close mortgage loans.
25. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did your institution’s average closing time (the period of time from loan
application to loan consummation) change? (Choose one)
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
26. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did your
institution’s average closing time (the period of time from loan application to loan
consummation) change? (Choose one)
Increased significantly
Increased somewhat
Remained about the same
Decreased somewhat
Decreased significantly
I don’t know
27. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, mortgage loans originated at your institution were…
More likely to close on the scheduled closing date
Less likely to close on the scheduled closing date
Equally likely to close on the scheduled closing date
21
If answered equally likely in question 27, skip question 28.
28. How long did the effect on closing times last?
Less than 6 months
6 months or more
22
Section 6
In this section of the survey we ask questions about mortgage loans after consummation.
The following questions are only about mortgage loans covered by the TRID Rule that your institution
originated which contained at least one error in the final disclosure provided to the borrower at or
before closing (either the HUD-1 settlement statement or the Closing Disclosure).
29. Thinking back to each of the following time periods, approximately what percentage of
mortgage loans covered by the TRID Rule match the above description?
Timeframe
a)
Percentage
October 2014 through October 2, 2015 (year before the
TRID Rule took effect)
b) October 3, 2015 through October 2016 (first year after
the TRID Rule took effect)
c)
Calendar year 2018
%
%
%
30. Thinking back to each of the following time periods, of the above described mortgages that
you sold, approximately what percentage were you able to sell at approximately the price
you originally expected?
Timeframe
a)
Percentage
October 2014 through October 2, 2015 (year before the
TRID Rule took effect)
b) October 3, 2015 through October 2016 (first year after
the TRID Rule took effect)
c)
Calendar year 2018
%
%
%
31. If applicable, what strategies did your institution use to sell the above described mortgages at
approximately the price you originally expected? (Mark all that apply)
Offered borrower a free refinance
Sold the mortgage loan to a different institution than originally intended at approximately the
original price
23
Cured the loan/disclosure
Other, please specify
32. If applicable, what strategies did your institution use to sell these mortgages at a price below
what you originally expected? (Mark all that apply)
Sold the loan at a reduced price (e.g., on the “scratch and dent” market)
Cured the loan/disclosure
Other, please specify
< New page >
33. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of mortgage loans that your institution kept in portfolio
change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not keep mortgage loans in portfolio before or after the
TRID Rule took effect.
I don’t know
If response indicates a change, then ask the following question. Otherwise, skip.
34. If applicable, did the TRID Rule cause the change in the percentage of mortgage loans that
your institution kept in portfolio? If so, how?
Yes: Free Response
No
I don’t know
24
< New page >
35. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of mortgage loans that your institution sold to GSEs change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not sell mortgage loans to GSEs before or after the TRID
Rule took effect.
I don’t know
If response indicates a change, then ask the following question. Otherwise, skip.
36. If applicable, did the TRID Rule cause the change in the percentage of mortgage loans that
your institution sold to GSEs? If so, how?
Yes: Free Response
No
I don’t know
< New page >
37. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of mortgage loans that your institution sold for inclusion in
Ginnie Mae guaranteed securities change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
25
Not applicable, our institution did not sell mortgage loans for inclusion in Ginnie Mae
guaranteed securities before or after the TRID Rule took effect.
I don’t know
If response indicates a change, then ask the following question. Otherwise, skip.
38. If applicable, did the TRID Rule cause the change in the percentage of mortgage loans that
your institution sold for inclusion in Ginnie Mae guaranteed securities? If so, how?
Yes: Free Response
No
I don’t know
< New page >
39. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of mortgage loans that your institution sold for inclusion in
private label securities change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not sell mortgage loans for inclusion in private label
securities before or after the TRID Rule took effect.
I don’t know
If response indicates a change, then ask the following question. Otherwise, skip.
40. If applicable, did the TRID Rule cause the change in the percentage of mortgage loans that
your institution sold for inclusion in private label securities? If so, how?
Yes: Free Response
No
I don’t know
26
< New page >
41. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of mortgage loans that your institution sold on the scratch and
dent market change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not sell mortgage loans on the scratch and dent market
before or after the TRID Rule took effect.
I don’t know
If response indicates a change, then ask the following question. Otherwise, skip.
42. If applicable, did the TRID Rule cause the change in the percentage of mortgage loans that
your institution sold on the scratch and dent market? If so, how?
Yes: Free Response
No
I don’t know
< New page >
If any questions in previous loop yielded a response indicating a change, proceed to this question.
Otherwise, skip.
43. You indicated that your institution’s changed. Did these
changes affect your institution’s ability to originate new mortgage loans? If yes, please tell
us why.
Yes: Free Response
No
I don’t know
27
Section 7
In this section of the survey we ask questions about products offered by your institution.
44. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of your institution’s originations that were home equity loans
(closed-end, not the primary mortgage) change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate home equity loans (closed-end, not the
primary mortgage) during either time period.
I don’t know
45. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of your institution’s originations that were home equity loans (closed-end, not the
primary mortgage) change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate home equity loans (closed-end, not the
primary mortgage) during either time period.
I don’t know
46. If applicable, did the TRID Rule cause the change in the percentage of your institution’s
originations that were home equity loans (closed-end, not the primary mortgage) If so, how?
Yes: Free Response
28
No
I don’t know
< New page >
47. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of your institution’s originations that were Home Equity Lines
of Credit (HELOCs) change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate Home Equity Lines of Credit (HELOCs)
during either time period.
I don’t know
48. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of your institution’s originations that were Home Equity Lines of Credit
(HELOCs) change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate Home Equity Lines of Credit (HELOCs)
during either time period.
I don’t know
49. If applicable, did the TRID Rule cause the change in the percentage of your institution’s
originations that were Home Equity Lines of Credit (HELOCs)? If so, how?
29
Yes: Free Response
No
I don’t know
< New page >
50. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of your institution’s originations that were construction loans
change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate construction loans during either time period.
I don’t know
51. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of your institution’s originations that were construction loans change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate construction loans during either time period.
I don’t know
52. If applicable, did the TRID Rule cause the change in the percentage of your institution’s
originations that were construction loans? If so, how?
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Yes: Free Response
No
I don’t know
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53. Comparing the year after the TRID Rule took effect to the year before the TRID Rule took
effect, how did the percentage of your institution’s originations that were manufactured
housing loans (secured by real property) change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate manufactured housing loans (secured by real
property) during either time period.
I don’t know
54. Comparing calendar year 2018 to the year before the TRID Rule took effect, how did the
percentage of your institution’s originations that were manufactured housing loans (secured
by real property) change?
Increased significantly
Increased somewhat
Stayed about the same
Decreased somewhat
Decreased significantly
Not applicable, our institution did not originate manufactured housing loans (secured by real
property) during either time period.
I don’t know
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55. If applicable, did the TRID Rule cause the change in the percentage of your institution’s
originations that were manufactured housing loans (secured by real property)? If so, how?
Yes: Free Response
No
I don’t know
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56. Were there products other than those listed above (HELOANs, HELOCs, construction
loans, or manufactured housing loans) for which your institution’s origination volume
changed substantially as a result of the TRID rule?
Yes
No
If Yes to previous question, proceed to the next question. Otherwise, skip next question.
57. For which products did your institution’s origination volume change substantially due to
the TRID Rule? Please explain.
Product Type (add
rows as necessary)
Originations
Originations
Increased
significantly
Decreased
significantly
Explanation
Free response
Thank you for taking the survey. We appreciate the time you devoted to making this a more informed
assessment. If you have any additional comments, please use this space to describe effects of the TRID
Rule that you think the survey may have otherwise missed.
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