One common TRID misconception surrounds when the Closing Disclosure (CD) can be provided. At a minimum, the CD must be in the applicant’s hand at least three business days before loan closing. Our Review Team often sees institutions that want to get a jump on things and provide the CD much earlier. While the CD can be provided earlier, it needs to be the actual CD. A lot of institutions use terms such as “initial CD” and “final CD”; however, the regulation doesn’t make or even allow this distinction. With only a few exceptions, a CD should not be issued with estimates or guesses; it is to include final numbers.
Jerod explains more in the video.
Published 2026/01/16
