TRID requires that the Closing Disclosure (CD) be received by the borrower at least 3 (precise) business days prior to loan closing. If any changes occur between when the CD is received and when the loan is closed, a revised or updated CD is to be provided at closing. As such, many financial institutions try to distinguish the “initial” CD from the “final” CD. However, under the TRID rule, there is no such distinction, just the CD. This idea of there even being an initial CD can easily lead to other issues. For example, lenders sometimes believe, when the CD is received prior to loan closing, that it just needs to be a preliminary (or estimated) disclosure, which is not the case. Again, the CD received prior to closing is the CD and is subject to a good faith standard, which means it needs to be as accurate as possible, based on the best information available.
Jerod explains more in the video.
Published
2024/04/22