TRID (the TILA-RESPA Integrated Disclosure rule) governs two mandatory waiting periods in the mortgage process. The Loan Estimate waiting period controls when a lender can impose fees. The Closing Disclosure waiting period controls when a loan can close. Both have specific triggers and counting rules that MLOs must understand to avoid costly delays.
The Loan Estimate Waiting Period
- ✦Lenders cannot collect fees beyond a bona fide credit report fee before the borrower has received and acknowledged the LE.
- ✦The LE must be provided within three business days of a complete application.
- ✦Borrowers must wait a minimum of seven business days after LE delivery before the loan can close.
- ✦This seven-day wait cannot be waived except in documented bona fide personal financial emergencies.
The Closing Disclosure Waiting Period
The CD must be received by the borrower at least three business days before consummation. For the CD waiting period, business day means any day open for business by the lender, including Saturday. For the seven-day LE waiting period, business day means all calendar days except Sundays and federal holidays. The different definitions apply to different waiting periods, which is a common source of confusion.
Change of Circumstance and Revised LE
A change of circumstance (COC) allows the lender to issue a revised LE with updated fees within three business days of learning of the change. Valid COCs include changed loan amount, property value different from the appraisal, new information about the borrower's employment, and acts of God affecting the transaction. After a revised LE, the applicable waiting periods restart for the changed fee categories.
Aria can walk through any TRID scenario, identify which waiting period applies, and confirm whether a revised LE is required for a specific change of circumstance. Ask at vicariointel.com.
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