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#2051221 - 11/24/15 06:34 PM Final invoices and closing disclosure
ADN Offline
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Joined: Mar 2007
Posts: 205
I am wondering at what point should we be issuing our closing disclosure (CD)? It seems we are issuing the CD and final invoices are still trickling in and then we are having to redisclose. Should we be waiting to issue the closing disclosure after the final insurance, final survey invoice, etc. come in?

Thanks for any input..

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TRID - TILA/RESPA Integrated Disclosures Rule
#2051224 - 11/24/15 06:45 PM Re: Final invoices and closing disclosure ADN
Truffle Royale Offline

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Posts: 17,359
I may be missing something because I don't know why you would give a CD that wasn't complete and final.
You should be issuing the closing disclosure in time for the borrower to get it three days prior to closing at which time you should have all of your invoices in hand.

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#2051231 - 11/24/15 06:57 PM Re: Final invoices and closing disclosure Truffle Royale
ADN Offline
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Joined: Mar 2007
Posts: 205
Thanks for the response. It is exactly what I thought. The processors are getting pressure to get the CD out so we can meet closing deadlines in the purchase agreement. We normally mail them out so there is still 7 days until the closing but in the mean time a few final bills are trickling in.

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#2051233 - 11/24/15 07:01 PM Re: Final invoices and closing disclosure ADN
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,864
Cape Cod
The obvious lesson here is that lenders are learning how difficult it is to coordinate all this stuff. The service providers are still getting used to the idea that they have about seven days less time to get stuff done and the invoices in the hands of the whoever is doing the closing disclosure, and you may need to get tough with some of them in order to get them to jump through those hoops.
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John S. Burnett
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#2051234 - 11/24/15 07:05 PM Re: Final invoices and closing disclosure ADN
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,864
Cape Cod
Unless the process is streamlined, there's going to have to be some give at one end or the other. Either service providers get their acts together sooner or real estate agents will have to lower sellers' expectations on the turnaround time required to get to closing. And the lender and settlement agent get squeezed in the middle.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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