TRID Data: Closing Costs, Consumer Confusion and Title Workflows
What CFPB, ALTA, NAR, lender and title-industry research reveals about TRID compliance costs, Closing Disclosure corrections, consumer understanding and the evidence still missing
There is no shortage of opinion about the TILA-RESPA Integrated Disclosure Rule. There is considerably less data.
That presents a problem whenever the Consumer Financial Protection Bureau considers changing TRID timing requirements, tolerance rules, Closing Disclosure forms, refinance rescission rights or requirements for small lenders. A rule can be cumbersome and still provide value. A process can become more expensive after a regulation takes effect without proving that the regulation caused every dollar of the increase. A disclosure can be frequently corrected without telling us whether those corrections helped consumers.
This article assembles the most useful published TRID research from the CFPB, American Land Title Association, Texas Land Title Association, National Association of REALTORS®, Fannie Mae, title technology providers and other industry sources. It separates what the evidence supports from what the available studies cannot establish.
The Short Answer: What Does the Published TRID Research Show?
The strongest available evidence supports five conclusions:
TRID created substantial implementation costs and appears to have increased ongoing coordination and disclosure-related costs for title and settlement companies.
Revised Loan Estimates and corrected Closing Disclosures are extremely common, but published data do not identify how many corrections are material to the consumer or how many actually delay closing.
Tolerance rules influence lender estimates, provider lists and decisions to absorb or refund settlement-cost increases.
Consumers continue to struggle with the federal presentation of title-insurance premiums and with understanding the closing documents they sign.
TRID initially lengthened closing times, particularly for purchase mortgages, but much of the measurable market-level disruption diminished as the industry adapted.
The evidence does not tell us how often borrowers exercise the right of rescission, what would happen if refinances funded immediately, how much title agencies spend maintaining different lender workflows, or what a small-lender exemption would cost the rest of the closing ecosystem.
Sources
CFPB, TRID Rule Assessment Report: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
CFPB, How Mortgages Change Before Origination: https://files.consumerfinance.gov/f/documents/cfpb_data-point_how-mortgages-change-before-origination.pdf
CFPB, Request for Information Regarding Promoting Access to Mortgage Credit: https://www.federalregister.gov/documents/2026/07/09/2026-13834/request-for-information-regarding-promoting-access-to-mortgage-credit
How Reliable Is the Available TRID Data?
No single study answers every question, and the sources do not all carry the same evidentiary weight.
The CFPB’s 2020 assessment is the most comprehensive source. It draws from nationally representative mortgage databases, borrower surveys, controlled consumer testing, supervisory information and several industry surveys. Its market-level analyses can measure changes around TRID’s October 3, 2015 effective date more reliably than a retrospective opinion survey.
The CFPB was nevertheless explicit that it could not complete a full cost-benefit analysis. TRID applied to nearly the entire covered mortgage market, leaving no clean control group of otherwise comparable transactions that remained unaffected. Other mortgage rules took effect during the same general period. Some industry data were voluntary, retrospective and not nationally representative.
The CFPB’s Closing Company Survey illustrates the limitation. It received 115 responses, and responding companies accounted for approximately 3.7% of 2015 mortgage-closing volume. Respondents were asked in 2019 and 2020 to recall costs and practices from several years earlier. The survey provides credible evidence of what participating companies experienced, but it should not be presented as a precise national estimate.
Other industry studies add valuable perspectives while introducing their own limitations:
NAR surveyed 1,014 randomly selected members, but the answers reflect real estate professionals’ observations rather than lender or title transaction records.
ALTA’s consumer research included 2,000 current and prospective homeowners, but it measured responses to disclosures in a survey setting rather than behavior during live closings.
TLTA published unusually detailed responses from approximately 125 title professionals, but the study was voluntary, Texas-specific and not formally weighted.
Fannie Mae surveyed 205 lenders shortly after implementation, making the results useful for understanding the transition but less reliable as evidence of current conditions.
Vendor studies from Qualia, PropLogix, Snapdocs and MetaSource provide useful operational evidence, but methodology and respondent details are not always fully disclosed in public summaries.
The best use of this research is cumulative. A finding becomes more persuasive when transaction data, consumer research and industry surveys point in the same direction. It remains important to state what each source measured and what it did not.
Sources
CFPB, TRID Rule Assessment Report, executive summary and data appendices: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
NAR, 2020 CFPB Closing Process Rule Survey: https://narfocus.com/billdatabase/clientfiles/172/21/3490.pdf
ALTA, TRID Title Insurance Fee Disclosure Confuses Consumers: https://www.alta.org/blog/post/survey-trid-leaves-consumers-feeling-confused-taken-advantage-of
TLTA, survey announcement and methodology: https://tlta.com/TLTA/TLTA/News_Publications/Dateline/2020/Dateline_081920.aspx
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How Much Did TRID Increase Title and Settlement Operating Costs?
The published evidence indicates that settlement-company costs rose by substantially more than ordinary inflation after TRID took effect. It does not prove that TRID caused the entire increase.
One-time TRID implementation costs
The CFPB calculated a median one-time implementation cost of approximately $39.20 per closing among closing-company respondents. The interquartile range was approximately $16.30 to $92.90. Smaller companies generally reported higher implementation costs per file: the median was approximately $90 per closing among firms in the smallest size quartile and $26.90 among firms in the largest quartile.
Respondents attributed the implementation expense primarily to:
Understanding TRID and revising policies and procedures: 27.7% of reported implementation costs;
Updating or creating information-technology systems: 26.4%;
Initial staff training: 18.9%;
Developing compliance tools, templates and job aids: 11.6%;
Reviewing relationships and renegotiating contracts: 4.3%; and
Other costs: 11.1%.
Ongoing cost per closing
The CFPB’s primary analysis—after excluding several outliers—reported that the median estimated cost of providing settlement services increased from $400 per closing before TRID to $500 during the first year after implementation and remained $500 in 2018.
The raw survey appendix, which includes responses omitted from the analytical table, reports a $350 pre-TRID median and a $500 post-TRID median. The CFPB’s own narrative and analytical table use $400 as the cleaner baseline, so that is the more defensible figure to cite.
The $400−to−$500 movement represents a 25% nominal increase. General inflation was nowhere close:
Using annual-average CPI as a reasonable approximation, $400 in 2015 had the purchasing power of approximately $405 in 2016.
By 2018, general inflation would have increased the $400 baseline to approximately $424.
The reported $500 cost in 2018 was therefore approximately 18% above the inflation-adjusted baseline.
Settlement work is labor-intensive, so private-industry compensation is another useful benchmark. Employer compensation costs generally increased about 2% to 3% annually during this period—roughly 8% cumulatively from 2015 through 2018. That would move a $400 labor-heavy baseline to approximately $432, still well below $500.
There is no BLS Producer Price Index specifically for NAICS 541191, Title Abstract and Settlement Offices. BLS identifies the industry as an area its PPI program does not cover. Consequently, no perfect settlement-industry inflation adjustment exists.
Which operational activities reportedly increased costs?
Among closing-company respondents providing usable answers, the CFPB reported:
94.2% said coordination with mortgage originators increased costs;
89.3% said changes in the number of revised disclosures increased costs;
87% said closing timing increased costs;
86% said consumer and real estate professional interactions increased costs;
78.8% said third-party coordination increased costs;
82% said training increased costs; and
56.2% said legal advice increased costs.
When nonresponses are retained in the denominator, the raw appendix produces the lower figures commonly quoted from the survey: 84.4% for lender coordination, 80% for revised disclosures and 75.7% for closing timing. The two sets of percentages describe the same responses using different denominators.
Did agencies pass the additional cost to consumers?
The evidence is less straightforward. Median reported revenue per closing decreased from $600 before TRID to $575 during the first year after implementation, then rose to $725 in 2018. The CFPB found that company-level increases in revenue were not significantly correlated with increases in reported ongoing costs. That means the survey does not establish that agencies simply added the TRID-related expense to consumer charges.
The most accurate conclusion is that the cost increase substantially exceeded inflation and appeared immediately after implementation, which is consistent with a TRID effect. The voluntary survey, retrospective estimates, possible changes in the services included and lack of a control group prevent assigning the full $100 increase to TRID.
Sources
CFPB, TRID Rule Assessment Report, pp. 109–116 and Appendix D: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
BLS, annual CPI-U data: https://www.bls.gov/regions/mid-atlantic/data/ConsumerPriceIndexAnnualandSemiAnnual_Table.htm
BLS, private-industry compensation costs through 2018: https://www.bls.gov/opub/ted/2019/compensation-costs-for-private-industry-workers-up-3-point-0-percent-in-2018.htm
BLS, areas not covered by the Producer Price Index: https://www.bls.gov/ppi/fd-id/areas-of-noncoverage-in-the-ppi-system.htm
How Often Are Loan Estimates and Closing Disclosures Revised?
Disclosure revisions are not exceptional. They are part of the normal post-TRID mortgage process.
The CFPB examined disclosure data from more than 50,000 mortgages originated between March 2016 and November 2017. It found:
Almost 90% of the loans involved at least one revised disclosure;
62% received at least one revised Loan Estimate;
49% received at least one corrected Closing Disclosure;
Approximately 57% received more than one Closing Disclosure;
Approximately 13% experienced a change in APR between the first and last Closing Disclosure; and
Almost half generated a post-closing Closing Disclosure.
Among loans receiving a post-closing Closing Disclosure, only about 1.1% showed an APR change and approximately 1% showed a finance-charge change. That suggests that many post-closing corrections involved administrative, nonfinancial or otherwise unmeasured fields. It does not establish that the corrections lacked consumer value.
NAR’s survey provides more context. When a Closing Disclosure was reissued, 39% of respondents reported a delayed closing and 1% reported a cancellation. Among respondents identifying a reason for reissuance, 73% selected a “minor error.” Examples included payoff adjustments, fees, closing dates, taxes and missing information.
Those findings expose a major gap in the debate. The industry knows that corrections are frequent. It does not have published transaction-level data showing:
Which party supplied the changed information;
Whether the change was financial, clerical or legal;
How much the change affected cash to close;
Whether a new disclosure was legally required or issued because of lender policy;
Whether the correction restarted a waiting period; or
Whether the consumer used the corrected information to change the transaction.
Current TRID rules restart the three-business-day waiting period only for a limited group of changes: an APR change beyond the applicable tolerance, a change in the loan product or the addition of a prepayment penalty. A corrected CD is therefore not synonymous with a delayed closing, even though lender procedures may create additional operational delay.
Sources
CFPB, How Mortgages Change Before Origination: https://files.consumerfinance.gov/f/documents/cfpb_data-point_how-mortgages-change-before-origination.pdf
CFPB, TRID Frequently Asked Questions: https://www.consumerfinance.gov/compliance/compliance-resources/mortgage-resources/tila-respa-integrated-disclosures/tila-respa-integrated-disclosure-faqs/
NAR, 2020 CFPB Closing Process Rule Survey: https://narfocus.com/billdatabase/clientfiles/172/21/3490.pdf
HousingWire, CFPB explanation of the limited redisclosure triggers: https://www.housingwire.com/articles/33864-cfpb-director-cordray-corrects-serious-misunderstanding-about-trid/
What Do Quality-Control Audits Reveal About TRID Errors?
Post-closing quality-control findings show that Closing Disclosure problems are recurring compliance issues, although the public data do not reveal their prevalence.
MetaSource reported results from tens of thousands of post-closing quality-control audits performed in 2018. Three of its leading findings involved the Closing Disclosure:
Closing Disclosure tolerance violations;
Errors in Calculating Cash to Close; and
Closing Disclosure timing violations.
Missing or defective written settlement-service-provider lists also appeared among the leading issues. MetaSource observed that some lenders generated multiple CDs for small changes even when another disclosure was not necessarily required.
The published summary ranks the defects but does not provide failure percentages. It can support the statement that tolerances, cash-to-close calculations and timing are persistent quality-control problems. It cannot support a statement that a particular percentage of mortgage files contains those defects.
The title-insurance calculation introduces its own reconciliation problem. ALTA has documented that the federal simultaneous-issue formula may cause the title premiums displayed on the CD to differ from the actual filed or promulgated charges. In seller-paid-owner-policy transactions, the federal presentation can also require additional credits or adjustments to make the Cash to Close section reflect the parties’ contract. Many title agencies use an ALTA Settlement Statement or state-required disclosure to show the amounts actually charged and paid.
Sources
ALTA, summary of MetaSource post-closing quality-control findings: https://www.alta.org/news-and-publications/news/20190131-Survey-TRID-Tops-Lender-QC-Issues
ALTA, simultaneous-issue title-premium disclosure: https://www.alta.org/blog/post/how-to-disclose-the-discounted-premium-on-the-integrated-mortgage-disclosure-forms
ALTA, seller-paid title insurance and Cash to Close: https://www.alta.org/blog/post/cfpb-indicates-how-to-disclose-title-insurance-premiums-in-seller-pay-scenarios
ALTA, use of supplemental settlement statements: https://www.alta.org/news-and-publications/news/20150924-How-to-use-ALTAs-Settlement-Statements
How Do TRID Tolerance Rules Change Lender Behavior?
The CFPB’s lender survey provides unusually direct evidence that tolerance rules affect estimates, provider selection and cure behavior.
In the CFPB’s voluntary survey of 99 mortgage originators:
71.7% said they sometimes, often or almost always estimated variable settlement fees at the top of the expected range to reduce the risk of tolerance violations;
65.7% sometimes, often or almost always gave consumers a written provider list containing only one provider;
79.8% sometimes, often or almost always absorbed or refunded charges that exceeded the applicable tolerance; and
Only 24.3% sometimes, often or almost always entered agreements with settlement providers to limit rate fluctuations.
These figures cover settlement services generally, not title charges alone. They nevertheless demonstrate two competing effects.
Tolerance rules encourage creditors to take responsibility for unreliable estimates rather than transferring every increase to the borrower at closing. At the same time, they encourage conservative estimates and may discourage lenders from presenting consumers with multiple service-provider options.
The data support targeted clarification for charges that genuinely cannot be known at application—such as some transfer taxes, recording charges or property-specific title services. They do not support eliminating tolerance discipline across broad categories of third-party charges.
Sources
CFPB, TRID Rule Assessment Report, mortgage-originator survey tables in Appendix D: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
CFPB, Regulation Z § 1026.19 and official interpretations: https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
Do Consumers Understand TRID and the Closing Disclosure?
The evidence is mixed on whether TRID improved mortgage comprehension overall. It is much clearer that substantial confusion remains.
The CFPB’s controlled testing found that the integrated forms improved participants’ ability to locate key information and compare loan offers and final terms. The National Survey of Mortgage Originations also found that post-TRID borrowers were more likely to describe forms as easy to understand and valuable. Those findings support preserving standardized, comparable disclosures.
Other findings are less reassuring:
Qualia’s independently conducted Homebuyer Sentiment Index surveyed 1,024 recent and prospective homebuyers. Only one in five recent buyers said they understood all the documents signed at closing.
44% of those recent buyers were surprised by higher-than-anticipated transaction costs.
One in four prospective buyers said they did not understand the closing process.
55% of prospective buyers wanted face-to-face information before closing, while 44% wanted information through a secure application or portal.
In NAR’s survey, only 24% considered the TRID forms more helpful than the prior forms; 26% considered them less helpful and 29% considered them about the same.
54% of NAR respondents believed consumers would benefit from receiving the CD earlier, even if it might later require revision.
These studies do not prove that TRID caused continuing confusion. They do show that the existence of a standardized form should not be mistaken for complete comprehension—and that removing review time would affect consumers who already struggle with the documents.
Sources
CFPB, TRID Rule Assessment Report, consumer-effects analysis: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
Qualia, Homebuyer Sentiment Index findings and methodology: https://www.qualia.com/press-releases/home-buying-surge-highlights-need-for-home-closing-consumer-resources/
NAR, 2020 CFPB Closing Process Rule Survey: https://narfocus.com/billdatabase/clientfiles/172/21/3490.pdf
Why Is the TRID Title-Insurance Calculation a Consumer-Understanding Problem?
The federal presentation of simultaneous-issue title premiums is one of the best-documented title-specific problems in TRID.
When an owner’s policy and lender’s policy are issued simultaneously, state-filed or promulgated pricing frequently discounts the lender’s policy. The federal formula instead displays the lender’s policy as though it were issued alone and presents the owner’s policy as the difference between the combined premiums and the full lender-policy charge. The total may reconcile when the buyer pays both premiums, but the individual lines do not display the transaction’s actual policy charges.
ALTA consumer research
ALTA commissioned a 2016 online survey of 2,000 current and prospective homeowners. Participants were shown compliant Closing Disclosures and then told the actual cost of the policies. ALTA reported:
31% said the presentation was confusing;
10% felt they were being taken advantage of;
Only approximately 27% reacted positively to seeing the owner’s policy presented as a marginal cost; and
More than half said they received information about title insurance at closing or did not know when they received it.
Consumers preferred a detailed breakdown of actual costs and the ability to compare estimated and final expenses over the federal marginal-cost presentation.
ALTA home-closing survey
ALTA’s two-phase Home Closing Survey covered more than 800 pre-TRID homebuyers and nearly 700 post-TRID homebuyers. It found:
92% of post-TRID buyers reviewed mortgage documents before closing, compared with 74% before TRID;
12% of post-TRID buyers were unsure whether they had purchased an owner’s title policy, compared with 8% before TRID; and
74% of post-TRID closings occurred as scheduled, compared with 77% before implementation.
Advance review improved, but more consumers remained uncertain about whether they had purchased their own title coverage.
Texas Land Title Association research
At the CFPB’s request, TLTA surveyed approximately 125 title professionals concerning the simultaneous-issue presentation. A large majority of the published responses estimated that consumers questioned or were confused by the calculation in 75% to 100% of affected closings.
Most respondents estimated that explaining the CD and the separate Texas Disclosure added approximately five to twenty minutes at the closing table. Many estimated another ten to thirty minutes or more to prepare, balance and explain the two documents. Agents repeatedly described using the state disclosure, an ALTA Settlement Statement, a premium report or a calculator to show what the parties were actually paying.
These are practitioners’ estimates, not a measured statewide consumer-confusion rate. Their value is operational: the responses consistently describe title professionals creating and explaining a second document to translate the federal presentation back into the transaction’s actual charges.
Sources
ALTA, TRID Title Insurance Fee Disclosure Confuses Consumers: https://www.alta.org/blog/post/survey-trid-leaves-consumers-feeling-confused-taken-advantage-of
ALTA, Home Closing Survey: https://www.alta.org/news-and-publications/press-release/ALTA-Survey-Shows-More-Homebuyers-Reviewing-Mortgage-Disclosures-
TLTA, survey announcement and methodology: https://tlta.com/TLTA/TLTA/News_Publications/Dateline/2020/Dateline_081920.aspx
TLTA, complete survey responses: https://tlta.com/common/uploaded%20files/documents/CFPBSurveyResults_July24andJuly31.pdf
TLTA, cover letter to the CFPB: https://tlta.com/common/uploaded%20files/documents/CFPBSurveyCoverLetter_Final_18Aug2020.pdf
CFPB, title-insurance disclosure factsheet: https://files.consumerfinance.gov/f/documents/cfpb_tila-respa_title-insurance-disclosures.pdf
Did TRID Cause Mortgage Closing Delays?
TRID produced measurable implementation-era delays. The strongest market-level evidence shows that the purchase-mortgage effect diminished within approximately two years.
The CFPB found that immediately after implementation:
Purchase-mortgage closing times increased approximately 13%;
Refinance closing times increased approximately 10%;
Purchase originations temporarily declined approximately 14%;
Refinance originations temporarily declined approximately 8%; and
Purchase closing times returned to their typical pre-TRID range within approximately two years.
The CFPB considered the causal evidence stronger for purchase transactions. Refinance closing times historically fluctuated enough that a 10% short-term change was not unusual.
Several early industry surveys reported larger effects:
Fannie Mae’s 2016 survey of 205 lenders found that 87% believed TRID increased closing time. Among those reporting an increase, the mean was 6.61 additional days and the median was five days.
Smaller lenders reported a mean increase of 7.72 days, compared with 5.89 days among larger lenders.
44% of Fannie Mae respondents said they raised borrower loan fees because of TRID.
A Callahan & Associates survey reported by HousingWire included more than 200 credit-union executives from 46 states. 96.1% reported delays, and the average closing time was 42 days against a 31-day goal.
Those studies measured the difficult transition immediately following implementation. They should not be used to claim that TRID continues to add five, seven or eleven days to the average mortgage closing.
More recent operational surveys show that unexpected delays remain important without isolating TRID as the cause:
In NAR’s 2020 survey, 30% said TRID had slightly decreased the ability to close on time.
PropLogix’s 2021 survey received more than 400 responses; 51.1% selected unexpected delays as a leading daily challenge, 41.7% selected excessive responsibilities and 40.4% selected insufficient time. Eighty-two percent of respondents were from Florida.
PropLogix’s 2024 research included more than 230 responses associated with more than 50,000 closings. Unexpected closing delays remained the second-ranked daily challenge, behind generating new business.
The defensible conclusion is not that TRID has no effect or that it permanently added a fixed number of days. TRID caused a significant transition, the measurable market-wide effect declined, and disclosure coordination remains one of several possible sources of file-level delay.
Sources
CFPB, TRID Rule Assessment Report, market-effects analysis: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
Fannie Mae, Lenders’ Experiences with TRID: https://www.fanniemae.com/media/19966/display
HousingWire, Callahan & Associates credit-union survey: https://www.housingwire.com/articles/36716-trid-causes-closing-delays-to-most-credit-unions/
NAR, 2020 CFPB Closing Process Rule Survey: https://narfocus.com/billdatabase/clientfiles/172/21/3490.pdf
PropLogix, State of the Title Industry reports:
https://stateoftitle.com/
Why Can’t Every Title and Settlement Charge Be Finalized at Application?
Current title-production research documents the amount of work that occurs between application and a reliable final figure.
ALTA and ndp | analytics collected 449 responses from title professionals across 47 states during 2025. The study found:
82% of purchase files and 59% of refinance files required review of more than ten documents;
21% of purchase files involved more than 50 documents;
27% of respondents still had to obtain some source documents in person;
Nearly 60% generally removed three to five commitment requirements or exceptions before closing;
More than 20% generally removed six or more requirements or exceptions;
Mortgage payoffs appeared in more than 90% of transactions;
59% identified obtaining releases for prior unreleased mortgages as a significant curative pain point;
35.9% identified obtaining and coordinating payoff information as a significant pain point; and
31.9% identified obtaining accurate information from transaction participants as a significant pain point.
The study does not measure how frequently a particular title or settlement charge changes between the Loan Estimate and Closing Disclosure. It does explain why some application-stage figures cannot be treated as finished invoices.
A title agency may not yet know whether a survey, release, corrective document, municipal search, additional endorsement, probate instrument or other curative service will be required. A payoff may change. A previously unreleased mortgage may appear. A public record may need to be obtained manually. The charge becomes knowable only after the underlying work identifies the requirement.
This evidence supports better lender-title data exchange and carefully drawn tolerance relief for information that objectively was unavailable. It does not support allowing placeholder estimates when the lender could have requested reliable information earlier.
Sources
ALTA and ndp | analytics, Measuring the Complexity of Title Production: https://tlta.com/common/Uploaded%20files/documents/CurativeWorkflowStudy2025_FinalReport.pdf
CFPB, Regulation Z § 1026.19: https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
How Fragmented Is Lender-Title Coordination?
Published vendor research suggests that the lender-title interface is already highly fragmented and communication-intensive.
Qualia and STRATMOR reported that:
Nearly one in four lenders worked with more than 100 title companies each month;
One in four spent more than 75% of their time coordinating and sharing information with title companies; and
One in four made more than 30 emails or telephone calls per loan.
The public summary does not disclose enough about the sample to treat those figures as national benchmarks. The findings nevertheless show why lender-specific exemptions or alternative disclosure rules may shift costs rather than eliminate them. A title agency closing for many creditors would need to identify which rules, timing standards, forms and correction procedures apply to each lender and each file.
NAR found visible downstream variation in existing practices. Buyer and seller information was separated on the CD in 55% of respondents’ markets; another 25% said the practice depended on the lender. That variation exists under one federal framework. Additional creditor-specific rules could multiply it.
Electronic closing technology has not eliminated the coordination problem. Snapdocs surveyed 100 large lenders in 2023 and found that 74% had invested in eClosing technology, but only 28% of the lenders offering eClosings had achieved adoption above 60%. Legal permission and software availability do not automatically produce consistent execution across creditors, settlement providers, notaries and investors.
Sources
Qualia/STRATMOR, lender-title coordination findings: https://blog.qualia.com/optimize-closing-margin-compression/
NAR, 2020 CFPB Closing Process Rule Survey: https://narfocus.com/billdatabase/clientfiles/172/21/3490.pdf
Snapdocs, State of eClose Adoption: https://www.snapdocs.com/resource-center/press-release/the-state-of-eclose-adoption
What Does the Evidence Say About Small-Lender TRID Relief?
The available research supports the proposition that smaller lenders experienced disproportionate implementation burdens. It does not establish that exempting them from uniform disclosures would reduce total transaction costs.
Fannie Mae’s early survey found that smaller lenders reported a mean closing-time increase of 7.72 days, compared with 5.89 days among larger institutions. The CFPB’s assessment also found that fixed implementation costs produced higher per-loan and per-closing burdens for smaller firms.
That evidence can support simplified guidance, longer implementation periods, common technology resources or carefully designed safe harbors. It does not answer the questions created by a small-lender exemption:
How would a title agency verify that a creditor qualifies?
Would eligibility depend on assets, annual originations, portfolio status or loan type?
Which disclosure, tolerance and timing system would apply?
What happens if the loan is sold?
Would investors impose their own overlays?
Would creditor savings be passed to consumers?
How much would title agencies and software providers spend supporting parallel workflows?
No published study located in this review measures those downstream costs. Claims that an exemption will reduce the consumer’s price should therefore be tested rather than assumed.
Sources
Fannie Mae, Lenders’ Experiences with TRID: https://www.fanniemae.com/media/19966/display
CFPB, TRID Rule Assessment Report: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
Qualia/STRATMOR, lender-title coordination findings: https://blog.qualia.com/optimize-closing-margin-compression/
What Does the Research Show About Reverse-Mortgage Disclosure Confusion?
Reverse-mortgage research documents substantial consumer confusion, but it does not identify which signing documents most often cause the problem.
The CFPB’s 2012 reverse-mortgage study found that consumers often struggled to understand:
That the loan balance generally increases over time;
That available home equity generally decreases as advances and charges accumulate;
That borrowers remain responsible for property taxes, insurance, assessments and maintenance; and
The circumstances that may cause the loan to become due and payable.
Urban Institute research also identified cost as a significant barrier. Citing a 2006 survey of counseled seniors, it reported that 69% considered reverse-mortgage costs somewhat or very high.
These findings support disclosures that show future balances, remaining equity and ongoing obligations in dollars under multiple scenarios. They also support a tailored explanation of non-borrowing-spouse issues, maturity events, payment plans and heirs’ options.
They do not establish whether the TALC table, counseling certificate, generic booklet, note, mortgage or another document is the principal source of confusion at signing. That question still requires targeted consumer testing and closing-level research.
Sources
CFPB, Reverse Mortgages: Report to Congress: https://files.consumerfinance.gov/a/assets/documents/201206_cfpb_Reverse_Mortgage_Report.pdf
CFPB, summary of reverse-mortgage consumer findings: https://www.consumerfinance.gov/archive/newsroom/consumer-financial-protection-bureau-report-finds-confusion-in-reverse-mortgage-market/
Urban Institute, Seniors’ Access to Home Equity: https://www.urban.org/sites/default/files/publication/88556/seniors_access_to_home_equity.pdf
HUD, Housing Counseling Program Handbook: https://www.hud.gov/sites/dfiles/OCHCO/documents/76101HSGHBK.pdf
Is There Published Data on Refinance Rescission Rates?
No credible national dataset located in this review reports how often homeowners exercise the right of rescission during the three-business-day period, either before or after TRID.
That missing denominator is critical. The absence of published rescission statistics does not prove that the right is unnecessary. It also prevents the industry from measuring the operational cost per rescission, identifying which borrowers use the protection or determining what problems are discovered after signing.
A meaningful analysis would require creditors and servicers to report:
The number of covered refinance consummations;
Rescission notices received;
Completed, withdrawn and disputed rescissions;
Rate-and-term versus cash-out transactions;
The reason for rescission, where voluntarily provided;
Whether fraud, elder exploitation, capacity, title, payoff or disclosure problems were involved;
The amount and destination of cash-out proceeds; and
The timing and cost of unwinding the transaction.
The existing data also do not establish the fraud, failed-funding, lien-priority, payoff or consumer-harm consequences of same-day refinance disbursement. Those risks should be measured before rescission rights are narrowed, particularly for cash-out refinances secured by a consumer’s principal dwelling.
Sources
CFPB, Regulation Z right of rescission, 12 CFR § 1026.23: https://www.consumerfinance.gov/rules-policy/regulations/1026/23/
CFPB, Request for Information Regarding Promoting Access to Mortgage Credit: https://www.federalregister.gov/documents/2026/07/09/2026-13834/request-for-information-regarding-promoting-access-to-mortgage-credit
CFPB, TRID Rule Assessment Report: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
The Most Important TRID Data Gaps
After reviewing federal research, land title association studies, real estate surveys, lender research, technology-provider reports and industry publications, several consequential questions remain unanswered:
How often do borrowers rescind a refinance during the statutory rescission period?
How many corrected Closing Disclosures result from late or incomplete lender information?
How many corrections involve material changes to cash to close, loan price or borrower rights?
How often does a corrected CD actually postpone consummation?
How much do title agencies spend maintaining creditor-specific workflows, portals, forms and closing instructions?
What would a small-bank or credit-union exemption cost settlement providers and software vendors?
Would any creditor savings be passed through to consumers?
What error, fraud, payoff, lien-priority or consumer-harm rate would accompany same-day refinance funding?
Which reverse-mortgage documents and concepts create confusion during the actual signing?
How frequently do consumers decline owner’s title insurance because of the federal presentation rather than an informed decision about coverage?
These are not minor academic omissions. They sit directly beneath several of the largest changes now being discussed. The appropriate response to a missing statistic is to collect it—not to treat the absence of evidence as evidence that a protection has no value.
Sources
CFPB, Request for Information Regarding Promoting Access to Mortgage Credit: https://www.federalregister.gov/documents/2026/07/09/2026-13834/request-for-information-regarding-promoting-access-to-mortgage-credit
CFPB, TRID Rule Assessment Report: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
October Research, Voice of the Title Agent:
https://www.octoberresearch.com/
What Should Policymakers and the Title Industry Take From the Data?
The published record does not support preserving every TRID procedure exactly as it exists. It supports fixing the parts that generate work without generating clarity.
The evidence is strongest for several targeted reforms: correct the federal title-insurance premium presentation; improve lender-title data exchange; distinguish material changes from clerical corrections; provide clearer changed-circumstance guidance; deliver reliable Closing Disclosures earlier; create transaction-specific forms for construction and reverse mortgages; and establish consistent standards for electronic delivery and proof of receipt.
The evidence is much weaker where the proposed change would remove a consumer right or create a second regulatory system. There are no published national rescission rates, no reliable estimate of the downstream cost of a small-lender exemption and no measured safety record for same-day refinance funding.
TRID’s costs are real. So are the benefits of receiving comparable estimates, holding creditors accountable for unjustified fee increases and giving consumers time to review final mortgage terms. The useful question is not whether TRID is good or bad. It is which requirements improve the consumer’s decision, which merely move information around, and who performs the additional work when a rule is described as “streamlined.”
The data can answer part of that question. The remaining answers will require the CFPB, lenders and the title industry to start measuring the work that has previously been treated as invisible.
Sources
CFPB, TRID Rule Assessment Report: https://files.consumerfinance.gov/f/documents/cfpb_trid-rule-assessment_report.pdf
CFPB, How Mortgages Change Before Origination: https://files.consumerfinance.gov/f/documents/cfpb_data-point_how-mortgages-change-before-origination.pdf
NAR, 2020 CFPB Closing Process Rule Survey: https://narfocus.com/billdatabase/clientfiles/172/21/3490.pdf
ALTA, 2020 TRID Assessment comment letter: https://www.alta.org/file/TRID-Assessment-RFI-Comment-Letter
TRID Data Review • July 2026 •
Stay Wicked,
Cheryl
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