Providing a Closing Disclosure Too Soon
The Closing Disclosure (CD) must be received by the applicant no later than three business days before loan closing. This means you must make a good faith effort to get the final costs included on that disclosure. If third parties, like title companies, etc., don’t get you the information, you can give an estimate, but only after you’ve made a good faith effort to get the actual costs. Further, if an estimate is used, an updated CD will likely need to be provided at or before closing. We see institutions run into problems when they issue the CD earlier than required. Final numbers likely aren’t ready at that point and so they issue the CD using estimated costs when, if they had waited, they might have final numbers. Issuing the CD too early often times doesn’t meet the good faith requirement.
Jerod explains more in the video.
Published
2024/12/10
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!