TRID Implementation Inconsistency Among Lenders Continues to Drive Title Agent Costs. The First American Real Estate Sentiment Index for the third quarter of 2016 found that lenders are inconsistently implementing the CPFB’s integrated disclosure rule, and that is driving up costs for title agents.... Mortgage Complaints Still High, But Drop Noticeably in 3Q16 From Year-Ago Levels. The latest monthly consumer complaint report from the CFPB found that mortgages remain among the top three sore spots for borrowers, but had a noticeable drop from the third quarter of 2015 to the same period this year....