Credit unions reported devoting considerable staff time and resources to comply with TILA-RESPA Integrated Disclosure regulations, effective on mortgage applications accepted after Oct. 3.
Mark Wilburn, chief lending officer at the $719 million, 71,000-member Truity FCU estimated that the Bartlesville, Okla.-based cooperative would spend an extra $50 to $60 per loan on hard costs for the additional procedures. He also said the credit union spent hundreds of hours researching vendor options, reviewing requirements, testing the new systems and training loan officers and processors.
According to the credit union's 5300 report, Truity originated 775 mortgage loans in 2014 for roughly $137 million. As of Sept. 30, 2015, the credit union originated 896 loans for $171 million. If the credit union originated those loans under the new rules, they would cost an additional $45,000 to $54,000.
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Wilburn said Truity was working with a vendor to improve its software integration with Truity's loan origination system so it would produce the necessary documents, but the vendor was still working out the bugs.
He also reported other credit union mortgage originators in his area were experiencing similar problems.
"I don't know of anyone who has actually closed a TRID loan yet," Wilburn said, adding he heard credit unions in other states had not had as many problems.
Mortgage staffers were manually processing mortgage applications until the kinks could be worked out, he said.
Carrie Wood, president/CEO of the 9,800-member, $59 million Timberland Federal Credit Union told a similar story. Testifying at an Oct. 28 hearing of the Senate Banking Housing and Urban Affairs Subcommittee on Financial Institutions and Consumer Protection, she described how her staff recovered an old typewriter from a closet to complete the required forms manually until vendor bugs could be worked out.
"With this particular change, we are vendor dependent to ensure our data processing system pulls all the right information into the correct fields on the forms," Wood said. "When we ran into an unanticipated problem after we flipped the switch to the new form, we were forced to manually input information into the new forms, slowing down the process for our members and potentially exposing us to errors."
Additionally, CFPB Director Richard Cordray signaled recently that the agency could take a hard line on software vendors that failed to help client financial institutions comply with the rules.
In prepared remarks at an Oct. 19 appearance at the Mortgage Bankers Association annual convention, Cordray said he was disturbed by reports he had heard about vendors.
"Some vendors performed poorly in getting their work done in a timely manner, and they unfairly put many of you on the spot with changes at the last minute or even past the due date," Cordray said. "It may well be that all of the financial regulators, including the Consumer Bureau, need to devote greater attention to the unsatisfactory performance of these vendors and how they are affecting the financial marketplace."
One credit union that reported few to no problems was the $31 billion, two million member State Employees' Credit Union. Senior Vice President for Loan Origination Services Stacie Walker said the Raleigh, N.C.-based credit union was ready to comply with new TRID rules since August.
"But of course, we were all right with the additional time, too," she said, chuckling.
The country's second largest credit union originated 23,000 mortgage loans in 2014 for more than $3 billion, according to its 5300 report. As of June 30, 2015, SECU originated more than 11,000 loans worth roughly $1.5 billion.
"I don't think I can help you much on costs since it's still so new," Walker said, explaining that the change did not change much regarding how SECU processed mortgages since it used similar steps when generating previous disclosure notices.
However, she echoed Wilburn in the observation that getting ready for the change had definitely carried a cost, and the cooperative will have to process mortgages under both systems for a while.
"We have mortgage applications that were filed under the old system and under the new," she said. "So we mark the outside of the file whether it's a [Good Faith Estimate] file or [Loan Estimate] file."
She added something that other credit unions shared as well: The involvement of third parties in the process was likely to raise the cost to the credit union initially, and then to members.
"We have heard that some of the closing lawyers have raised their prices," Walker said. "We have not raised any of our mortgage fees, but if outside costs creep up, that is liable to work its way back to the member."
The $1.1 billion, 74,000-member Financial Partners Credit Union also reported being ready early after working very hard to maintain its service standard.
Chief Lending Officer Michael Patterson reported Financial Partners was ready before Oct. 3, but required enormous effort.
Patterson said the credit union checked and double checked its mortgage systems and their output, both internally and with external compliance experts. In addition, the credit union's quality control staff spent a lot of time on the project, and Patterson said he anticipated adding another full-time quality control position to the mortgage team.
According to the its 5300 report, Financial Partners originated 866 loans for roughly $205 million in 2014 and originated 1,122 mortgage loans for roughly $274 million as of Sept. 30, 2015.
John Murphy, vice president for mortgage lending at the 67,000-member, $647 million Consumer Credit Union, reported his institution would be ready to close its first loan under the new rules by the end of October.
Murphy said the credit union's IT and operations teams split their time on weekends and after hours preparing for the transition.
Like Walker, Murphy also said vendors created scheduling complications and could potentially raise costs. The credit union collected Realtor information such as name and license numbers early in the process, he reported, because too often the sales contracts were not legible.
"The days when you could find a problem relatively late in the process, and then fix it and remain on schedule have passed," he observed.
Murphy also described a recent encounter with a Realtor who assured the credit union that a given home sale was not going to be under the new rules because the contract was signed in mid-September.
"Of course the application was signed on October 5th," Murphy said.
Finally, Navy Federal, the nation's largest credit union, reported it closed its first loan under the new rules Oct. 26. Katie Miller, vice president of mortgage lending, explained the cooperative still didn't have a firm idea on how much the new rule would add to the cost of a new mortgage.
"We are definitely interested in the question and have an analytic team looking into that," Miller said.
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