Under the old (pre-TRID) rules, if a loan was subject to both TILA and RESPA, an early TIL disclosure had to be given within 3 days of application. That was the only required TIL disclosure for the loan unless the APR became inaccurate, in which case a new disclosure had to be provided and there had to be three business days' wait before consummation. That all implemented MDIA. Under TRID rules there are two required disclosures and disclosure times, the LE and CloD. The CloD is the final disclosure of the rate and APR unless the APR become inaccurate after the CloD is delivered, in which case a new CloD has to be delivered, with a three-day waiting period from its receipt. Gone is the need to create a new LE when the rate's changed -- a CloD is issued anyhow, and that has a three-day wait attached, so it takes care of MDIA unless the APR on the CloD becomes inaccurate.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8