Skip to content

TRID Required Wait Times Confusion

Answered by: 

Question: 
I have an auditor questioning the timing of the revised Loan Estimate and loan consummation. I informed auditor that the borrower was sent revised Loan Estimate four business days prior to consummation and that is in line with the regulation; and the 7 business days requirement references the initial Loan Estimate (not revisions) --- Am I understanding the regs correctly or not?
Answer: 

Regulation Z section 1026.19(e)(4)(ii) sets out the timing requirements for a revised loan estimate.

1. A revised loan estimate cannot be provided on or after the date on which you provide the closing disclosure.

2. The consumer must receive any revised loan estimate not later than four (precise definition) business days before consummation.

3. If the revised loan disclosure is not provided in person, the consumer is considered to have received the revised loan estimate three (precise definition) business days after you deliver it or place it in the mail.

4. The second and third requirements can combine to make you send the revised loan estimate seven (precise definition) business days before consummation. If you have documentation of the consumer's receipt of the revised loan estimate less than three business days after you sent it, you can reduce the seven business days to as few as four (for example, if you had complied with E-SIGN and sent the revised loan estimate electronically and the consumer provided a receipt dated the same day).

First published on 02/26/2023

Filed under: 
Filed under lending as: 

Search Topics