United States
Hong KongThe TRID timeline
Loan Estimate within 3 business days of application and at least 7 business days before consummation. Closing Disclosure at least 3 business days before consummation. Only three changes restart that wait: APR beyond tolerance, a product change, or an added prepayment penalty.
More questions come out of this timeline than any other single thing on the paper. It is worth being able to draw it from memory.
The sequence
| Event | Deadline |
|---|---|
| Loan Estimate delivered | Within 3 business days of a complete application |
| Loan Estimate before consummation | At least 7 business days |
| Closing Disclosure delivered | At least 3 business days before consummation |
| Right of rescission (refinance) | 3 business days after consummation |
Four deadlines, three of which are three business days. That is the whole difficulty.
What starts the clock
A complete application, which under 12 CFR 1026.2(a)(3) means six specific items: name, income, social security number, property address, estimate of value and loan amount sought.
Not five, and not a lender's own idea of a complete file. Once all six exist you have an application whether anyone intended it or not.
What restarts the three-day wait
Three things, and only three.
- The APR becomes inaccurate beyond tolerance
- The loan product changes
- A prepayment penalty is added
Everything else - a fee moving, a seller credit changing, a corrected name - requires a corrected Closing Disclosure but does not restart the three business days. Questions are built on candidates assuming any change resets the clock.
Tolerance, briefly
Zero tolerance for the creditor's own charges, for services the consumer cannot shop for, and for transfer taxes. Ten percent cumulative tolerance for recording fees and for third-party services the consumer may shop for.
The APR tolerance itself is 0.125 percent on a regular transaction and 0.25 percent on an irregular one.
How to hold it
Draw it. One line, application at the left, consummation at the right, each deadline marked against it, and the three restart triggers written underneath.
Rebuild it on a blank sheet until it comes out complete in under two minutes.
Common questions
When is the Loan Estimate due?
Within 3 business days of a complete application, and at least 7 business days before consummation.
When is the Closing Disclosure due?
At least 3 business days before consummation.
What restarts the three-day waiting period?
An APR change beyond tolerance, a change of loan product, or the addition of a prepayment penalty. Nothing else.
What counts as an application under TRID?
Six items: name, income, social security number, property address, estimate of value and loan amount sought.
What are the tolerance levels?
Zero for the creditor's own charges, services the consumer cannot shop for and transfer taxes. Ten percent cumulative for recording fees and shoppable third-party services.