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Here we are, in Week 44, the last week of the project research and budget-approval phase of the Lender Implementation Timeline.

How many of you have completed this phase?

If you’re on track with the timeline, you’ve now achieved an understanding of what you’re facing over the coming months in order to get ready for Aug. 1, 2015. If you’re not on track, you now have the first challenge in your plan of playing catch up. Not a good place to be when this is only the first phase.

Over the last few weeks we’ve discussed the key area of a digital transformation known as Operational Process, an area that TILA-RESPA disrupts the most. During last week’s posts, we continued this discussion, starting with some relatively recent metricst hat you should absolutely know by now in your organization. In general, the MBA found:

  • The net cost to originate a loan grew to $3,540 from $2,827
  • Independent mortgage banks pulled in average profits of $346 per loan on originations last quarter, compared to an average profit of $1,082 per loan in the fourth quarter.
  • Personnel expenses rose to $3,640 per loan, up from $3,124 per loan in the fourth quarter.

As we discussed those metrics, we turned to a few questions to invoke some thinking among your organization:

  • What do you see in your organization today that could be improved from an operational process perspective?
  • What portions of your operational process are dependent on business partners outside of your immediate organization?
  • What can be improved in that area to help you do business smarter, faster and cheaper?
  • How is TILA-RESPA, and the 3-day loan estimate delivery and tolerance rules, going to change that for you?

In addition to how those numbers come into play with Operational Process, it’s also important to remember how much you’re spending to acquire a customer as opposed to keeping a customer. To do this, we started by looking at a few interesting facts when it came to a variety of companies across industries, and how much they spend on acquiring a customer:

  • Travel: $7
  • Telecom: Sprint PCS: $315
  • Retail: $10
  • Financial: TD Waterhouse: $175

Which ultimately leads to the question: Do you know what it fully costs you to acquire a customer? It is now critical that you know this metric today, because it’s going to change on Aug.1, 2015. If your operational processes are not streamlined, your margins are going to suffer even more when TILA-RESPA is effective.

For more information, visit to view a growing knowledge base of information and forums where you can ask questions and interact with others in this industry.

All information and views expressed or implied are provided without warranty and are only the opinion of Pavaso, Inc. Each participant should seek legal representation for legal interpretation of the ruling and the CFPB directly for final instruction and interpretation.The final rule can be found here.