“It is without question the single largest implementation challenge that the broad industry has faced since Dodd-Frank,” said David Stevens, president of the Mortgage Bankers Association, speaking to the effort put into conforming to TRID. “It’s massive. It involves every real-estate agent, settlement-service provider, every consumer, mortgage originator, everyone.”

Quicken Loans Inc., the third-largest U.S. mortgage lender by volume according to Inside Mortgage Finance, has had about 350 employees working for 17 months to change over to the new federally mandated processes and forms, said Bill Emerson, chief executive for Quicken.

“Clearly if we weren’t doing that, we’d have folks deployed on other projects, maybe things that would be innovative. But there’s no choice. You have to do it,” said Emerson, who said Quicken is prepared for the change.

Still that work is just a part of operating in the current market, argue critics.

“Filling out two documents instead of four and transparently disclosing the full costs of a mortgage doesn’t sound like an insurmountable problem to me,” says Barry L. Ritholtz, an opinion writer for Bloomberg News. “I doubt the industry-wide cost was one-tenth of the billions being claimed.”

Some of the changes that are coming include a three-day grace period between disclosure and the mortgage signing.

Since home transactions often are made together, as home buyers sell their old homes, a delay in one home closing can cause a ripple effect, says the National Association of Realtors President Chris Polychron.

“Are there going to be some blips? Yeah,” said Polychron. “Are there going to be some delays? Absolutely.”

Those concerns were accommodated when the implementation of the new rules were moved to October 3 from the August launch date.

But the rules are necessary, writes Ritholtz in the September 30 Bloomberg article, given the confusion many homebuyers had when signing mortgages, and the number of unqualified buyers that were given loans.