How long has your staff been on their jobs? The Fed has kept short term rates unchanged for 6 years and 9 months at this point. Does your senior management team have plans in place, or estimates of the impact on business, if (or when) that stance changes? No one owns a crystal ball, but at some point it is bound to change. "At some point" is a safe bet - time has a way of passing us by. In fact anyone who has been in the business less than 7 years wasn't even around when Countrywide existed as we knew it - but the company made news again as "The Only Banker Sued for the Housing Crisis Prepares her Appeal."

The CFPB is pushing "Know Before You Owe" but the industry knows it as TRID...

Two business days in and TRID news has been interesting. Paul P. writes, "Someone asked me how we're doing with all the new regulatory changes. My response was, 'So far we are just TRIDing water.'" And someone else said there's a rumor that in the hallways of the CFPB TRID stands for "Thoroughly Rolling in Dough" referencing future enforcement actions.

"Hi Rob, I heard that Wells Fargo is out of the FHA 203k and HARP business, along with a couple other origination products, for a while due to TRID issues... wondering if you heard anything on that." Yes, that is true, and you can bet competitors are using that to their advantage. And you can bet it doesn't reflect well on senior retail management especially after they gave assurances to their staff and the public that Wells' retail was prepared for October 3^rd. Better get IT on the phone...

On the other end of the public relations scale some savvy companies have already turned TRID preparedness into a marketing topic. Out of Gulfport Mississippi I received this blurb from the director of mortgage lending at Hancock and Whitney Banks Mauro Harto:  "At Hancock Bank and Whitney Bank...streamlined processes and a three-point promise to clients are already helping the Hancock and Whitney mortgage teams get homebuyers set for closings in 29 days or less.

"TRID absolutely benefits the consumer and helps them better understand the financial commitment of buying a home. It's designed to ensure no surprises for the client," said Mauro Harto, director of mortgage lending at Hancock and Whitney. "Our Hancock Bank and Whitney Bank mortgage teams have made it our priority to make sure we're ready to meet our promise to help homebuyers close in 29 days or less, guide them through every step, and provide helpful, clear communication during the entire process."

Created by the Consumer Financial Protection Bureau (CFPB), the new mortgage rule combines two 40-year-old laws-the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA)-into one consumer-oriented TILA-RESPA Integrated Disclosure rule (TRID). This new "Know-before-You-Owe" rule requires lenders to provide clients clear, easier-to-understand disclosures earlier in the home buying process.

Harto said well-managed workflows, regular communication, and common-sense courtesy are keys to meeting or exceeding TRID requirements.

"Many people in the industry estimate closings could take up to 75 days. Our experience at Hancock and Whitney already contradicts that misunderstanding, showing TRID is nothing to fear," added Harto. "The client must do their part and provide complete information on time. We help the client know those expectations up front, with the same kind of consideration we would expect as clients. We've already seen that we can ready a client for closing in 29 days or less with a simpler, easier, better mortgage experience."  

Hear more TRID insights from Harto at https://youtu.be/1mDb_24XyP0.

And TRID training continues. "Now that TRID is in effect-- are your real estate partners on board? We've got a FREE Top Tips TRID Guide for Real Estate Agents.  When you or your partners purchase online TRID Training from Strategic Compliance Partners and Morf Media Inc. for only $25 per person this week, you'll get just the ticket to move forward with TRID success. Top industry trainer Ginger Bell has developed the toolkit to get your partners on board. Order online at: http://morflearning.com/trid-training/ or please call Call Heidi Deishl at 571.201.0579 to learn more about the TRID Training and multi-pack company savings. Prices will go up to $49 next week. Act now. Get TRID training at $25 between now and Oct. 13, 2015.

(And Ginger writes that the "additional 3 business day waiting period" is often incorrectly interpreted. "The lender will need to add on an additional 3 business days to count for delivery of the Closing Disclosures by mail. This means that from the day the lender places your buyer's Closing Disclosures in the mail they will count a total of 6 business days before your buyer can sign their closing documents.")

With the rise of TRID, Ellie Mae has added additional resources and information to keep you compliant in its resource center. Also available are RESPA-TILA FAQ and eLearning courses to introduce the new concepts.

NYCB's Mortgage Consulting Center's is providing phone menu options for urgent TRID inquiries. Available at 888-321-6446, "Press 1" for time-sensitive, loan-specific TRID questions or to "Press 2" for all other questions. Please select the appropriate menu option to ensure that your inquiry is routed to those Mortgage Banking Consultants who have the subject-matter specialization to best assist you.  Again, this new TRID menu option is designed to provide you with priority service regarding an urgent, loan-specific TRID question. For general TRID questions, view training resources and WebEx courses available.

DocMagic announced that PHH Mortgage has signed a multi-year license agreement to use its expansive set of products to help ensure compliance with the TILA-RESPA Integrated Disclosure. Expanding on its technology and compliance solutions, DocMagic has developed SmartCLOSE, which can integrate with loan origination systems for seamless, bi-directional exchange of data and related information. Additionally, it will integrate with all leading settlement technology platforms and other third party applications used in the loan closing process to allow all relevant parties to share, validate, audit, track and collaborate on documents, data and fees in a secure, collaborative environment. Dominic Iannitti, president and CEO of DocMagic, stated "We have designed SmartCLOSE to be the most advanced and effective TRID solution in the industry. That is why we can rep and warrant all documents and calculations generated in SmartCLOSE with a TRID Compliance Guarantee."

Kinecta let clients know that they could click on this link below to learn how to submit TILA-RESPA Integrated Disclosure (TRID) loans with complete applications (dated October 3 or after) to Kinecta.

Last but not least Fannie Mae and Freddie Mac released guidance to their sellers outlining the GSEs' expectations regarding compliance with TRID. The GSE guidance largely conforms with the statements issued last week by the CFPB and the federal banking agencies outlining a good faith compliance standard during the initial implementation phase of TRID. "... considerable technological and operational challenges...numerous compliance questions that remain outstanding...expect lenders to make good faith efforts to use the new forms and complete them accurately, but they will not be conducting routine post-purchase loan file reviews focused on technical compliance with TRID.  But lenders still need to use the correct forms, not impede the enforcement of the note, and so on. It is best for lenders to read the actual announcements from Fannie and Freddie.

As a reminder last month the California Bureau of Real Estate (BRE) issued a Licensee Advisory regarding providing the Mortgage Loan Disclosure Statement (MLDS) in light of the new TRID rule and implementation. The MLDS is a disclosure required under California Business & Professions Code Section 10240 from a mortgage broker to a borrower of the maximum costs and expenses associated with obtaining a loan. The MLDS must be provided within 3 days of the broker or agent receiving a borrower's completed written loan application. In most cases, as of October 3, 2015, a Loan Estimate that meets the requirements of and is compliant with TRID will also meet the requirements of California Business & Professions Code 10240(c) and 10236.4, as long as the borrowers adhere to certain criteria.

Turning to boring interest rates, they seem pretty happy (as if the market has a personality) where they are. Rates improved slightly Tuesday despite a strong rally in energy prices and the release of August trade figures which showed the United States' deficit widening more than expected. A strong dollar (which hurts demand for U.S. exports) and the slowdown in emerging markets were credited with the deteriorating trade position. The $24 billion 3-year note auction was met with good demand, despite drawing a lower-than-average bid-to-cover ratio.

I head out early to Dallas and then Des Moines today, and it is too early to know where the market is exactly. There isn't much scheduled data: The MBA's mortgage application index, which never moves rates. Our government will sell off $21 billion in 10-year T-notes. Speaking of 10-year notes they closed Tuesday with a yield of 2.04%.

Jobs and Announcements

An independent mortgage banker based in the southeast Michigan/Detroit area for 30+ years is seeking an experienced candidate to fill the role of Chief Operating Officer. The Company's management and new investors aim to grow origination volume to $5+ billion organically and through acquisition in the next two-to-five years, and to increase retained MSRs to roughly the same level.  As a direct FNMA and FHLMC Seller-Servicer and a GNMA approved issuer, the Company provides a full suite of conventional and products, and services its loans in-house. The successful COO candidate will be a proven leader who can drive internal operations improvement initiatives that increase scalability and customer responsiveness as the Company expands its retail, wholesale, and correspondent channels. Please send confidential resumes to me and specify opportunity. (Excuse response delays due to travel in Texas and Iowa.)

On the production side "are you a retail mortgage loan officer looking to join a successful bank with a strong product offering, competitive pricing, and significant income potential? Nationally chartered MB Financial Bank currently has opportunities in several states for retail branches, loan officers, and producing teams. If you're hungry and are looking for a chance to grow in your lending career, we are the place to do it! Contact Mike O'Brien, Mortgage SVP, to see how you could become a part of MB. Our leadership team has extensive retail branch experience, and is dedicated to growing and nurturing MB's retail presence nationwide. We provide you competitive compensation, quality benefits, internal training, marketing support, servicing portfolio leads, and generous tiered commission compensation plans - all to promote your success." MB Financial Inc. is the Chicago-based holding company for MB Financial Bank, N.A., which has approximately $16 billion in assets and a 110-year history of building deep and lasting relationships with middle-market companies and individuals. We are proud to be an Equal Employment Opportunity/Affirm. Action employee (Minority/Female/Disabled/Veterans). Equal Housing Lender and Member FDIC. NMLS#401467

A quick congrats to Nick Imbimbo. First Guaranty Mortgage Corporation, a Virginia Corporation, has named Nicholas Imbimbo as its Director, TPO Operations. (And I thought I received a lot of razzing about my last name growing up!)

If you're in the Northeast next week openings are still available for the AnnieMac Sales Summit at Caesars Atlantic City Hotel & Casino on October 14. "But they're going fast, so those who are interested in attending should sign up now. More than 300 have already registered for the event, which will feature some of the top speakers in the industry, including Rick Ruby, Steve Grossman, Craig Strent, Brent Hicks and Gibran Nicholas! Apply what you learn. Get inspired. Grow your business. It's all waiting for you at the AnnieMac Sales Summit."