Skip to content

Is a Final Closing DIsclosure Mandatory?

Is the Final Closing Disclosure mandatory to provide? If the lender provides Initial CD and the revised CD based on a Change of Circumstance and the borrower signs it, or the presumed date is over, can I skip the Final CD and provide the borrower only closing loan documents? Situation: Initial CD was issued on 10/1. The revised CD with COC was issued on 10/6 and the borrower will sign the loan docs on 10/6. Borrower will sign Revised CD and the loan docs at the same time. Is it possible?

by Randy Carey:

The borrower must receive a correct CD before closing. Whether that CD is delivered three business days prior to closing or a revised CD sometime before closing or at the time of closing. Only delivery is required and signatures on a CD is a lender option.


by John Burnett

The only timing issue in your scenario is whether the CloD reflecting the changed circumstance adjustments was received by the third business day (general definition) after learning of the changed circumstance, but no later than consummation.

First published on 10/30/2021

Filed under: 
Filed under lending as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics