Let's start off with a little quiz that I gave to my cat Myrtle. There are four business days left until a) Y2K b) New LO comp rules C) QM d) The Rapture e) TRID f) the Mayans saying civilization will end. Myrtle had that "We've been through big dates before" look as she correctly guessed (e), and then went on to suggest that any lender who hasn't, by this late date, been given everything they need by their vendors for full testing had better think about a different vendor in the future. The endless TRID news continues a few paragraphs down. We've had a lot of lead time but lots of folks seem to be pulling all-nighters out there...

Returning to the topic that has gripped residential lending all year - RESPA-TILA changes - I wonder what we'll talk about after the TRID-dust settles. The MBA did a survey over the weekend asking about TRID readiness. "Two-thirds said their companies are ready with little or no worry.  But one-third had insufficient time to test, integrate and train. Almost half of the individual companies say they are concerned that will be significant problems for their consumers. And half of these industry leaders say the overall impact of TRID the next few months - based on their own experience and what they know about industry implementation efforts - will be significantly negative for consumers ("...significant numbers of home purchase transactions will blow up or close late, adding a cost burden to resolve)."

The MBA went on. "Based on these results, the rule could have a significant negative impact on consumers. This not what the industry or CFPB wants, but it is clearly a concern. We do believe the "'Know Before You Owe' rule will make the mortgage process better for consumers, but the implementation has proven more difficult than expected. The rule was more complex than industry and CFPB anticipated, much of it due to the complexity of the technology and systems industry has put in place over the years, and the challenges of integrating separate systems across the industry. Consumers should be protected from these transition risks. Using the tools available to educate them should be a priority.

Zelman and Associates published their August Mortgage Originator Survey indicating improvement in underwriting standards and a 15 percent YoY increase in purchase applications in August, with the YTD average at 13 percent. Applicant credit quality index dropped to 64.1 in August from 64.4 in July, reaching the lowest level since mid-2012. The average credit score for securitized purchases was 725 in August compared to 730 a year ago and 735 two years ago. Credit availability has improved 27 percent since mid-2014 due to the removal of certain overlays and adopted proposals, as entry-level credit availability reached 63.7, up from 63.2 in July and 55.2 a year ago. On average, lenders ranked their preparedness for TRID at 86.2 on a scale of 100 (extremely prepared), which is an improvement from 72.6 back in March.

Prospect Mortgage is doing its part. All You Need to Know about TRID" is a free, educational webinar for Real Estate Agents and Settlement Service Providers offered by Prospect Mortgage. Get the scoop regarding the October TRID deadline and how it could impact closings this autumn. Audience members can submit questions during the one-hour webinar and get answers, live during the presentation. Register for the 9/30 session at www.LearnwithProspect. com.

Caliber Home Loans Wholesale Division is offering live TRID Training for Brokers via webinar through Friday October 2^nd, Caliber Wholesale Broker TRID Training will be held weekdays, twice a day at 10 am CDT and 2 pm CDT.  To register, click here and select the session that is most convenient to you.

Federal credit union Kinecta's TRID forms are posted for use on or after October 3rd.

Washington State's Evergreen Home Loans is hosting on its Evergreen Insights Blog on the Oct. 3 TRID changes. The podcast features insights from David Floan, executive vice president, loan production for Evergreen Home Loans.

Mortgage banking reporter Brad Finkelstein penned a head-turning piece titled, "TRID Lets Borrowers Sue Lenders Over Third-Party Vendor Lists". Just what we need, right? The article discussed new liabilities under the Consumer Financial Protection Bureau's integrated mortgage disclosure rules. "...the regulations that combine the Truth in Lending Act and Real Estate Settlement Procedures Act mortgage disclosures will put the requirement for lenders to provide borrowers with a written list of third-party service providers under the auspices of TILA, opening the door for borrowers to sue lenders for alleged violations...others have wondered whether the CFPB could use new data in the TRID forms to track interactions between loan officers, real estate agents and settlement agents."

NYCB is providing procedural overviews related to the generation and delivery of the NYCB Loan Estimate and Closing Disclosure. These procedures are also discussed in greater detail in our Webex training courses available from the TRID section of NYCB's Regulatory Newsroom. The implementation of LE and CD delivery solution will be a phased approach beginning with a manual process (i.e., in person, fax and U.S. Mail) to be quickly followed by electronic delivery options.

Nationstar's updated Seller Guide is now available. Updates include TILA/RESPA Integrated Disclosure Rule (TRID,) communications library and resources to help you comply.  Nationstar Mortgage has introduced the TILA/RESPA Integrated Disclosure Rule (TRID) Frequently Asked Question (FAQ) that provides information on some of the initial questions received. This FAQ document will be a living document and will be updated with new questions and answers, as they are received.

A lender, Country Bank, a Massachusetts-based mutual savings bank, has chosen Simplifile as its TILA-RESPA Integrated Disclosures (TRID) collaboration solution. Through Simplifile, Country Bank will have the ability to share changes, updates, deficiencies, and statuses with their settlement agents in one system, facilitating a fully auditable, more transparent process from loan application through automated delivery of the final title policy. Simplifile Collaboration and Post Closing are both free services to settlement agents. Interested Agents can register online.

NYCB Mortgage Table Funded Loans Registered before 10.03.15 with an AU submission as of Friday, 10.02.15 at 11pm ET, will continue to follow legacy "Pre-TRID" rules (i.e. must use GFE, HUD, and TIL forms and comply with RESPA and Reg Z requirements). All Table Funded loans without an AU submission or any loan where the 'Prequal' indicator is selected as "Yes" (on Gemstone's Registration) as of 10.02.15 at 11pm ET will be automatically deleted from the pipeline. A new registration may be submitted when Gemstone is available on Monday, 10.05.15 at 7am ET. For all locked loans, NYCB will be contacting Clients directly to discuss any specific pipeline requirements.

With so many upcoming industry changes, brokers are encouraged to review LDWholesale's weekly newsletter. Several TRID resources are available including a pre-recorded training session entitled, Introduction to TRID, a TRID FAQs document and a TRID Comparison Table to highlight the main differences pre and post TRID. In addition, LDW has another training session scheduled for September 22 at 10:00 am PDT to cover changes made to its broker portal in preparation for TRID. Brokers can register here.  Also released is a HUD Handbook Fast Facts guide designed to consolidate new HUD Handbook policy changes.

Let's shift up to something less complicated, like the bond markets. First a clarification! I commented yesterday that Caliber Home Loans privately sold the market's first non-qualifying RMBS this summer. It was actually Lone Star Funds backed by mortgages originated by Caliber Home Loans.

Did you know that superfast, nonbank trading firms account for 60% of activity in the most active corners of electronic Treasury trading, up from 45% in 2012? Some worry these new market participants are harming trading in Treasuries, creating unnecessarily volatility and "toxic" prices. Meanwhile, the reduction in sell-side trading desk capacity is exacerbating the problem (market depth in Treasuries is 30-40% below pre-crisis levels as a result of fewer sell-side participants).

Sure enough, government officials were surprised to learn that automated trading strategies account for about 50% of Treasury trading volume on a given day. One requirement gaining traction in the regulatory community is the creation of a continuously updated data feed that the gov't could use to track trading patterns. Officials may also subject Treasury trading platforms (ICAP PLC's BrokerTec and Nasdaq's eSpeed) to the same type of oversight now applied to stocks. How's that working out?

Looking at rates, U.S. fixed-income securities (Treasuries, MBS, and the like) rallied sharply Monday. Once again it was attributed to investors fleeing equities amidst concerns about global growth and putting their money into "risk-free" securities. Sure personal spending beat estimates in August while personal income missed, indicating a lower-than-expected savings rate. Still, no matter - rates went down. But we're still in the range we've been in since early August (2.10-2.20% on the 10-year T-Note yield).

Today for delectable economic news we'll have the July (July?) Case-Shiller 20-City Index at 9AM EDT, and September Consumer Confidence at 10AM EDT. But there are no "early" numbers that tend to move the markets. If you want to guess where rate sheets are heading, we closed the 10-year at 2.10% and this morning we're at 2.11% with agency MBS prices worse a couple tics (32nds). Still in the range we've been in for nearly two months...

Jobs and Announcements

In management jobs, Indecomm, "known as a sales leader in outsourcing, technology, training and support to the mortgage industry," is looking for a national sales director for its learning division lead by Alice Alvey. Duties will include selling Indecomm Education, Professional Services, Consulting and Doc Management Solutions to new and existing customers, meeting specific goals and targets for new sales and maintaining relationships with multiple contacts in each account on various business matters. The ideal candidate will have a good working knowledge of mortgage banking and relationships with midsize and large mortgage companies on a national basis that can be leveraged. Confidential resumes should be directed to Linda Bomar, Vice President of Sales (214.515.0848).

In correspondent news LenderLive Correspondent Lending is actively seeking experienced regional account executives in Southern California, Colorado, Texas and the mid-Atlantic region. LenderLive provides private-label, end-to-end mortgage services, from origination through default. LenderLive's correspondent program is a fast-growing, FNMA, FHLMC, GNMA seller/servicer providing a full product suite that includes non-QM. Their correspondent program offers a truly distinctive value proposition, including a Fast Track seller approval that activates clients in days rather than weeks. In addition, they are also the ICBA's Mortgage exclusive correspondent lending partner, with access to nearly 4,000 community banks nationwide. In addition to their compensation plan, LenderLive correspondent account executives have the ability to earn additional income cross-selling affiliate services. Contact Bob Kallio for more information. 

And on the wholesale side Carrington Wholesale Lending is expanding in Henderson, Nevada. "This is a great opportunity for an inside sales Account Executive and that we provide leads, set up appointments and a professional office environment.  You will have the ability to call on brokers throughout the Western US, base commission, and unparalleled benefits."  Contact Matt Evans, Divisional Sales Manager - West, at 949-517-6033.

Commenting on recent production trends he's seeing with a slant toward what Michigan Mutual is doing, Dr. Rick Roque, Managing Director of MiMutual Mortgage, dba of Michigan Mutual, Inc., writes, "Applications surged over the last 7 days due to the Federal Reserve's decision not to raise interest rates which left borrowers actively taking advantage of this temporary hold which kept lenders busy prior to the seasonal slowdown of the winter months. With total new application volume increasing 14%, this is welcome market support for refinance production teams, but again, the focus for MiMutual is purchase, driven mortgage professionals in markets across the United States, but going deeper is important for mortgage lenders. Most lenders add too many overlays going overboard with an exaggerated notion of 'risk' rather than embracing the unique public mission that lenders enjoy by having their HUD and GSE (Fannie, Freddie, and Ginnie) designations. 

"The intent of these government institutions is precisely to accomplish specific social and economic goals only accomplished through home ownership, something 99% of non-depositories (mortgage banks) have forgotten; for these mortgage lenders, it is profit over potential for home consumers across the U.S.  At MiMutual Mortgage, we have made a conscious decision to expand our CONDO offerings understanding frequently this is the 'starter home' for many borrowers.  And secondly, our effort to expand our loan officer and new office leadership in states like Arizona, New Mexico, Texas, Oklahoma and Florida, expresses our commitment to Hispanic, Foreign National  and minority borrowers, in addition to standard VA, FHA and Conventional consumers as well. If you are a licensed mortgage professional in these markets, who subscribe to this social mission of our professional, for a confidential discussion, contact Dr. Rick Roque  (413.297.6895)."