The TILA-RESPA Integrated Disclosure rule implementation in 2015 had potential to be the iceberg to the Mortgage industry’s Titanic. TRID was the biggest regulation change in twenty years and those companies not ready for the new way of doing business risked sinking their ship.

I originally posted this on LinkedIn back in 2016.

At Open Mortgage, several departments worked on TRID-related projects as their top priority in 2015 but I was most heavily involved in one: migration to a new loan operations system.

In late 2014, we decided that our best choice was to migrate from our existing in-house LOS to one provided by a third-party. After a survey of the market and evaluation of more than a dozen products and a vote by senior staff, we made our pick and started implementation of a new LOS in January 2015.

By late spring we were having doubts about our selection. We were missing key implementation deadlines and our vendor was struggling with some of our custom development requirements. By June the iceberg was looming large and it looked like our Titanic was in trouble.

Then we got lucky: CFPB extended the TRID implementation deadline to October 3rd. We terminated our existing implementation and gave ourselves 30 days to find a new solution. Our original survey & evaluation was updated and we selected a new partner (our runner-up from the original selection) with a implementation kick-off call on July 27th.

Turning the Titanic

So how do you turn the Titanic and implement an entirely new operations system for your company’s largest department in just 60 days? Here are the things I learned from both our failed and successful implementations:

Have a Great Team

Pulling the plug on a project that has been running for six months can cause confusion and fear. I’m lucky to work with a group of people that accepted the reality of our situation and embraced the challenge of the project. The mentality wasn’t “Can we do it?”, but instead “We can do it.”

Large projects like this also require support of the whole organization. Managers and subject matter experts will be needed outside of their current roles to contribute. Executives need to maintain support and head-off any roadblocks. Everyone needs to be flexible.

If you don’t have great people in your organization to manage a rapid implementation, make sure your partner does.

Pick the Right Partner

We chose LendingQB for many reasons, but key among them was their confidence and demonstration that we could move our implementation forward as fast as we could manage it from our side. Short timelines don’t only strain you, they strain the resources and process of your partners. Make sure your partners have done it before and have a well defined execution plan.

The right vendor won’t just work as fast and as hard as you do, but will also recommend opportunities to streamline and improve processes. If your vendor doesn’t have a Professional Services group or doesn’t offer these services, find a consultant experienced with the implementation to avoid pitfalls.

Communicate to Create Momentum

When you terminate an ongoing project, you’ve lost all of your momentum and create uncertainty. Restoring that momentum is key to building confidence in the new direction.

While it is tempting to put your head down and try to work as quickly as possible, effectively communicating the plan and progress will create momentum that increases buy-in and drives the project forward.

When I announced the termination of our first implementation, I laid out a clear next step (market re-evaluation) and deadline (30 days). Even small decisions completed by deadline will help create momentum. Explaining the plan at the outset will also reduce time spent answering those questions.

Streamline the Decision Making Process

There are too many decisions on a large project for each to be made by committee. Key to our success was installing the right people and giving them power to make independent decisions.

In our failed implementation, a group of eleven stakeholders met regularly to update progress and determine key implementation details like workflow and roles.

In our successful implementation, one implementation lead consulted with subject matter experts in one-on-one meetings to answer implementation questions. By making one person responsible for the whole picture, they could be dedicated full-time to the project and reduce the workload by only engaging with others as-needed.

Minimize Customization

Find a solution that best fits your existing process out-of-the-box. LendingQB has an excellent set of Lean Lending Best Practices that closely mirror our own process, but inevitably special customizations need to be made.

Carefully evaluate customization to determine if there’s benefit to changing the existing practices instead of customizing the product. Nothing as large as a loan operations system will have an out-of-the-box configuration that matches your existing practices exactly. Each difference is not only an opportunity to customize the product, but also to change and improve your practices.

At Open Mortgage, we wanted to change our existing initial loan disclosure workflow. LendingQB presented an alternate workflow and early on we decided that our lending practices would change, instead of working to customize LendingQB. This choice saved us implementation time and also improved our lending practices.

Happy Sailing

We missed the iceberg: our first live loan from our beta group went into LendingQB 50 days after our implementation began and that loan closed and funded. But more importantly, by October 3rd we had a TRID-compliant loan operations system in place.

Hopefully my experience here can help you next time you have your own Titanic to turn.