PwC continues to provide client guidance to integrate TRID process and procedures. Happy to Discuss. Tom Gere, Managing Director, PwC Thomas.gere@pwc.com

1. TRID Industry
Landscape: Risks and
Considerations
April 22, 2016
ww.pwc.com

2. PwC
TRID – Post Implementation Industry Landscape
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Partnership
Capabilities
Implementations were Imperfect. Even with the delayed implementation date,
many struggled to achieve compliance by October 3rd
. TRID projects continue into 2016
as lenders seek to address issues with systems and processes.
Cost of Compliance is Significant. Putting aside one-time costs associated with
implementation of the rules, the costs of ongoing compliance are proving to be high.
Many creditors cite adding new roles/functions, increased cycle times, and increased
quality control processes as key contributors to increased costs.
Inconsistent Approaches to Compliance. The results of the survey show that many
creditors interpreted and/or operationalized the rules differently. The inconsistency in
approach across creditors is causing concern for private investors and challenges in the
secondary market.
Uncertainty Permeates. Despite comments from the CFPB that “good faith efforts”
to come into compliance with the rules will be considered during examinations, creditors
and investors remain uncertain of how the rules will ultimately be enforced.
Since the effective date of the TRID requirements on October 3, 2015, several prominent
trends in the industry have emerged.

3. PwC
TRID – Secondary Market
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Partnership
Capabilities
Some of the biggest concerns regarding TRID compliance have come from the secondary
market.
Dynamics
• Due diligence firms performing detailed reviews for compliance with TRID
requirements for loans being sold to private investors (both for whole loans and
securitization) report high rates of errors.
 Errors types vary significantly, including timing violations, form/format of
disclosures, and tolerance.
• Private investors demonstrate the unwillingness to purchase loans with any level of
TRID error, requiring for issues to be fixed prior to purchase (time consuming and
costly), or rejecting loans with issues which cannot be cured.
• Repurchase risk is heightened. Some large correspondents have been in the news
for going out of business due to volume of repurchases.

4. PwC
TRID – Retail
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Partnership
Capabilities
Many continue to work on improving internal processes and controls to better manage
compliance with requirements and enhance operational effectiveness. Many may not be
aware of the extent of the errors being made.
Dynamics
• Loans held on balance sheet or sold to GSEs are not typically subject to the level of
compliance review performed on loans sold to private investors.
 Detailed compliance reviews are typically heavily manual, imposing
significant additional cost to origination.
 Regulators, however, will expect for loans to be compliant regardless of
business model.
• Ineffective fee management is causing for significant increases in RESPA cure
payments to consumers.
• With imperfect implementations, many are seeking ways to enhance processes and
controls to increase efficiency and reduce costs.

5. PwC 5
Partnership
Capabilities
What Should You Do?
Complete Integration with CMS. The CFPB has commented that initial
examinations will focus on Compliance Management Systems, so thorough
integration is required, including development of controls, KPI, KRI and other
metrics for ongoing reporting. Demonstrate active identification of issues and
rapid remediation.
Prioritize Enhancements. Identify processes which result in negative
impact to the consumer and prioritize these for enhancement following the
remediation of any compliance related issues.
Document “Good Faith”. In response to CFPB comments to consider good
faith efforts to come into compliance with the rules, develop a narrative report
to document implementation approach and compliance with the rules in a
clear and concise manner.
Conduct Loan File Reviews. Engage an unbiased third-party to review
closed loans for compliance with the Rules, especially for wholesale and
correspondent channels.
Reconfigure Quality Processes. Explore opportunities to automate costly
QC processes, eliminating costly redundancies from the business.

6. Thank you!
his publication has been prepared for general guidance on matters of interest only, and does
not constitute professional advice. You should not act upon the information contained in this
publication without obtaining specific professional advice. No representation or warranty
(express or implied) is given as to the accuracy or completeness of the information contained
in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its
members, employees and agents do not accept or assume any liability, responsibility or duty
of care for any consequences of you or anyone else acting, or refraining to act, in reliance on
the information contained in this publication or for any decision based on it.
© 2016 PricewaterhouseCoopers LLP. All rights reserved. In this document, “PwC” refers to
PricewaterhouseCoopers LLP which is a member firm of PricewaterhouseCoopers
International Limited, each member firm of which is a separate legal entity.

7. Thank you!
his publication has been prepared for general guidance on matters of interest only, and does
not constitute professional advice. You should not act upon the information contained in this
publication without obtaining specific professional advice. No representation or warranty
(express or implied) is given as to the accuracy or completeness of the information contained
in this publication, and, to the extent permitted by law, PricewaterhouseCoopers LLP, its
members, employees and agents do not accept or assume any liability, responsibility or duty
of care for any consequences of you or anyone else acting, or refraining to act, in reliance on
the information contained in this publication or for any decision based on it.
© 2016 PricewaterhouseCoopers LLP. All rights reserved. In this document, “PwC” refers to
PricewaterhouseCoopers LLP which is a member firm of PricewaterhouseCoopers
International Limited, each member firm of which is a separate legal entity.