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When costs shift gradually: What tariffs and regulatory change have in common

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Industry News
Tuesday, December 16, 2025

By Mary Schuster, October Research Chief Knowledge Officer

How much did your company have to pay to become TRID compliant?

In every industry, there are moments when external forces change the cost of doing business. Sometimes those forces arrive with a press release. Sometimes they arrive buried in hundreds of pages of new requirements. Either way, the question for companies is the same: Who absorbs the cost?

In lending and closing, we have lived through this before.

When major regulatory changes reshaped disclosure, timing, and compliance expectations, technology providers were forced to re-engineer systems, workflows, and safeguards — often on aggressive timelines. And with no concrete roadmap of what was right and what was wrong.

Contractually, many of those providers were obligated to absorb the costs of “keeping the client compliant.” Practically, it was also the right thing to do. The goal was stability: protect clients, avoid disruption, and keep the market moving.

The first wave — RESPA Reform — was manageable. Painful, yes — but survivable.

The second wave — TRID — was harder.

And across the software world, many of us held our breath behind the scenes, hoping there would not be a third.

By then, margins were thinner, resources were stretched, and the math no longer worked the same way. Another round of unfunded mandates would have forced a different conversation — one where costs could no longer be absorbed invisibly and would have to be shared downstream.

That dynamic is not unique to financial services.

Across a wide range of industries today, companies are facing new cost pressures that originate outside their control — supply-chain disruptions, compliance changes, or trade-related costs. In many cases, businesses initially try to absorb those costs themselves. They renegotiate contracts. They delay hiring. They defer raises. They trim investment elsewhere. They do everything possible to shield customers from price increases.

But absorption has a limit.

At some point, continued cost pressure stops being a short-term challenge and becomes a structural one. When that happens, the choice is not philosophical — it is operational. Costs either get passed along, or the business itself becomes unsustainable.

What is often missed in these conversations is how discreetly this process unfolds. Consumers do not see the meetings where companies debate whether to hold prices steady for one more quarter. Clients do not see the internal spreadsheets modeling what happens if costs increase again. They only see the moment when prices finally move — or when a provider exits the market altogether.

In lending and closing, we have already seen how this plays out. Compliance costs do not disappear; they migrate. Sometimes they surface as higher fees. Sometimes as fewer technology options. Sometimes as market consolidation. The intent behind the change may be well-meaning, but the economic reality still asserts itself, eventually.

The same pattern applies elsewhere. Businesses can — and often do — absorb shocks temporarily. But long-term cost shifts eventually show up somewhere in the system.

None of this is an argument for or against any particular policy. It is simply an observation grounded in experience: when costs change, someone pays. Sometimes that payment is immediate and visible. More often, it shows up later — in ways that are harder to trace back to the original cause.  In lower wages, a slowing economy, or a sluggish housing market.

What tends to get lost is the lag. The space between the decision and the impact. The months or years when companies try to make it work without passing costs along, hoping stability will return before tougher choices are required. That period is rarely public, but it matters.

Those of us who have lived through RESPA Reform and TRID recognize the pattern. The early adjustments. The internal strain. The moment when absorption stops being a strategy and starts being a risk. It is not unique to our industry — it is how systems respond when external costs keep stacking up. Which is why moments like this deserve attention. Not because they demand immediate action, but because they offer perspective. We’ve seen how these stories unfold before — and experience shows that what seems small at first often becomes clearer only in hindsight.

As we welcome the third consecutive cut in interest rates (and we do!), it’s worth remembering the many pressures shaping the housing market. Rising costs, regulatory requirements, and evolving expectations continue to ripple through every part of the system.

Just like with RESPA Reform and TRID, everyone in this economy is balancing obligations, priorities, and practical realities. While the TRID changes didn’t always result in immediate increased hard costs for you, your costs were still there — embedded in time, attention, and operational adjustments. There was an undeniable price, even if it wasn’t always visible.

Sometimes clarity lies below the surface.  Stay with us, to stay informed.  Beyond mere headlines, we understand.

Read more from Schuster in her blog, Tuesdays with Mary, here.

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