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.
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