One area of confusion that we see with the TRID Rule has to do with the accuracy of the information provided on the Closing Disclosure (CD). It’s pretty common for us to hear lenders refer to the “initial” CD and the “final” CD, yet the Regulation really doesn’t provide for or even mention there being two versions of the CD. There is one CD that is to be received at least three business days prior to loan closing. The information on that CD must be the best information available and, with limited exceptions, reflect the actual terms and costs of the transaction. As we all know, things do often change at the last minute and, if that happens, the Rule provides guidance on how and when to revise that CD. If nothing changes, there is technically no need to provide another CD at closing. In other words, the CD received three business days before closing is THE only CD that’s required, unless there are changes.
Jerod explains more in the video.
Video Highlights:
- The CD must be received three business days before closing and include the best information available at that time.
- Third parties can complicate the process, but lenders still need to try and get accurate information before issuing the CD.
- If something changes after the CD is issued, the CD can be revised in certain circumstances.
