TRID Rate Lock: When a Revised Loan Estimate Is Due

A Loan Estimate can be issued before the borrower locks an interest rate. If the rate is later locked, the creditor may need to update disclosures so the consumer sees the actual rate-dependent charges and terms. Regulation Z §1026.19(e)(3)(iv)(D) requires a revised version of the Loan Estimate disclosures no later than three business days after the rate is locked when the original disclosures were provided without a lock.

This is a specific TRID timing rule. It is different from a changed circumstance that increases a third-party charge and from the rules for corrected Closing Disclosures. A rate lock itself is the event that triggers this particular update when rate-dependent charges were not fixed on the original Loan Estimate.

When the three-day clock starts

The clock starts on the date the consumer and creditor enter into the rate-lock agreement. The creditor must provide the revised disclosures no later than three business days after that date. Use the Regulation Z business-day definition applicable to the rule; do not assume every calendar day counts or that a weekend can be ignored without checking the definition.

The requirement matters when the original Loan Estimate was delivered with the interest rate floating. The revised disclosures reflect the rate now locked and update rate-dependent charges and terms. If the original estimate already reflected a locked rate, the creditor uses the original disclosed rate-dependent amounts for the good-faith comparison unless another valid reason permits revision.

What the revised estimate reflects

The revised Loan Estimate should reflect the new interest rate, discount points disclosed on the form, lender credits, and other charges or terms that depend on the rate. The creditor should update the relevant disclosures consistently rather than changing unrelated fees without a separate valid reason.

The lock can change the points or lender credits offered for the selected rate. Those values are compared with the revised estimate for good-faith purposes when the lock occurs after the first Loan Estimate. A creditor should retain documentation of the initial estimate, lock agreement and date, revised estimate, delivery method, and actual charges.

Example

On Monday, a lender issues a Loan Estimate with the rate unlocked and no discount points. On Thursday, the borrower locks a rate that carries points and changes the lender credit. The lender must issue a revised Loan Estimate reflecting the locked rate and affected rate-dependent terms within three business days after the lock date. The exact deadline depends on the applicable business-day count.

If the borrower locks after the Closing Disclosure has already been provided, the lender cannot send a revised Loan Estimate on or after the date it provides the Closing Disclosure. It must address any resulting inaccuracies through a corrected Closing Disclosure. A new three-business-day waiting period before consummation is required only for the limited changes in §1026.19(f)(2)(ii), including an APR becoming inaccurate, a loan-product change, or adding a prepayment penalty.

The Closing Disclosure cutoff

A revised Loan Estimate cannot be delivered on or after the day the creditor provides the Closing Disclosure. Also, a revised Loan Estimate must generally be received no later than four business days before consummation. If it is not provided in person, the consumer is generally deemed to receive it three business days after delivery or mailing under Regulation Z’s timing rule.

This means a rate lock close to consummation may need to be reflected on the Closing Disclosure instead. The lender should not send a late revised Loan Estimate to reset a fee comparison after the Closing Disclosure cutoff. If the Closing Disclosure becomes inaccurate, apply the correction rules and determine whether a new waiting period is required.

Rate lock extension or expiration

A rate-lock extension can create its own disclosure question if it changes points, credits, or other charges. Regulation Z includes a separate changed-circumstance provision for a rate-lock extension requested by the consumer. The lender should identify whether the event is the initial lock, an extension, or expiration, then apply the corresponding subsection and document the terms.

If the consumer does not indicate intent to proceed within the permitted period, the expiration provision may allow updated estimates under its own conditions. That is not the same as the three-day rate-lock update. Keep the triggering event clear in the file and do not combine distinct reasons for revision.

Operational checklist

Record whether the first Loan Estimate was issued locked or floating. Capture the lock date and agreement. Calendar the three-business-day deadline. Update only the rate-dependent terms for this reason and deliver the revised disclosure. Check whether the Closing Disclosure cutoff has passed; if so, use the correct CD correction process. Retain the versions and proof of delivery.

Before closing, compare the rate, APR, points, lender credits, and payment across the lock confirmation, revised Loan Estimate, and Closing Disclosure. A clear chronology prevents both late disclosure and unsupported fee changes.

FAQs

Does every rate lock require a new Loan Estimate? The special update applies when the initial Loan Estimate was provided before the rate was locked.

What is the deadline? No later than three business days after the rate-lock date under §1026.19(e)(3)(iv)(D).

Can a revised Loan Estimate be sent with the Closing Disclosure? No. The rule prohibits providing it on or after the date the Closing Disclosure is given.

Does a rate-lock change always restart the three-day closing wait? No. The new waiting period applies only to specified corrected Closing Disclosure changes.

Additional underwriting and file considerations

One frequent operational error is treating the lock confirmation as if it were the required disclosure. The lock agreement records the rate and lock terms, but it does not replace the revised Loan Estimate when Regulation Z requires one. Another error is sending the estimate within three calendar days without checking the rule’s business-day definition and deemed-receipt requirements. The creditor should calendar both the preparation deadline and any consumer-receipt deadline.

A lock can also change the consumer’s payment and APR, which affects the Closing Disclosure. Compare the final locked rate to the figures already disclosed and determine whether any corrected CD is needed. Only certain changes require a fresh three-business-day waiting period; routine fee or rate corrections may require a corrected disclosure without a new wait. Follow §1026.19(f)(2) instead of assuming every correction restarts the clock.