What are common MLO exam mistakes on trid: le & cd timing?

Restarting the 3-day CD clock for every corrected figure. The fix: Only APR-out-of-tolerance, product change, or an added prepayment penalty restart the wait — a fee tweak needs only a corrected CD. Forgetting the mailbox rule. The fix: Mailed disclosures are received 3 business days after mailing — plan closings from the deemed-receipt date. Applying 10% tolerance fee-by-fee. The fix: The 10% test is aggregate across the category, not per charge.

How long does this lesson take?

About 14 minutes to read, plus a ten-question check in the free course.

TRID: LE & CD Timing

~14 min read · Run the 3-day Loan Estimate, 7-day waiting, 3-day Closing Disclosure clocks and tolerance buckets.

TRID fused TILA and RESPA disclosures into the Loan Estimate and Closing Disclosure — and wired them to clocks: 3 business days to deliver the LE, 7 to wait before closing, 3 more for the CD. Add the tolerance buckets, and you have the most math-testable rule set on the exam.

The application trigger and the LE

A TRID application exists when the lender has six items: name, income, Social Security number, property address, estimated property value, and loan amount sought. Within 3 business days of application, the Loan Estimate must be delivered or placed in the mail; consummation may not occur until at least 7 business days after LE delivery/mailing. The LE may not be conditioned on documents beyond the six items, and fees (beyond a reasonable credit-report fee) cannot be collected before the applicant indicates intent to proceed.

Six items = application: name, income, SSN, address, value, amount
LE within 3 business days; 7-business-day wait before closing
Only a credit-report fee before intent to proceed

The CD and its 3-day rule

The Closing Disclosure — final terms and costs — must be received at least 3 business days before consummation. Mailing adds time: documents sent by mail are deemed received 3 business days after mailing. A new 3-day waiting period is triggered by only three changes: the APR becomes inaccurate beyond tolerance (generally 1/8 point on regular loans), the loan product changes (fixed→ARM), or a prepayment penalty is added. Other cost changes need a corrected CD but restart no clock. For these waiting periods, 'business day' means all days except Sundays and federal holidays.

CD received ≥3 business days before consummation
Mail rule: received 3 business days after mailing
New 3-day wait only for: APR out of tolerance, product change, prepayment penalty added

Tolerance buckets

The LE binds the lender through three buckets. Zero tolerance: lender/broker charges, fees paid to affiliates, and services the borrower cannot shop for — any increase is refunded. 10% aggregate tolerance: recording fees and third-party services where the borrower selects from the lender's written provider list — the CATEGORY may rise up to 10% in total. Unlimited: prepaid interest, escrow deposits, owner's title (optional), and services where the borrower shops off-list. A valid changed circumstance (rate lock, borrower-requested change, new information) allows a revised LE within 3 business days, resetting the baseline.

Worked example

LE shows: origination $2,000 (zero bucket); recording + lender's title via list-selected providers $1,000 (10% bucket). At closing: origination $2,150, the 10% category totals $1,180. The CD was mailed the Friday before a Thursday consummation (no holidays). Any violations?

Zero bucket: origination rose $150 — zero tolerance means any increase without a changed circumstance is a violation; the lender must cure by refunding $150 at or within 60 days after closing. Ten-percent bucket: $1,000 → cap is $1,100; $1,180 exceeds it by $80 — refund $80. Timing: mailed Friday → deemed received 3 business days later, Saturday–Monday–Tuesday count (Sundays excluded): received Wednesday; consummation Thursday gives only 1 business day after receipt — the 3-business-day-from-RECEIPT requirement fails; closing must move to at least the following Monday. Three separate TRID tests — two tolerance refunds and one calendar — in one file.

Common exam pitfalls

Restarting the 3-day CD clock for every corrected figure.

Only APR-out-of-tolerance, product change, or an added prepayment penalty restart the wait — a fee tweak needs only a corrected CD.

Forgetting the mailbox rule.

Mailed disclosures are received 3 business days after mailing — plan closings from the deemed-receipt date.

Applying 10% tolerance fee-by-fee.

The 10% test is aggregate across the category, not per charge.

3-7-3: three days to the LE, seven to the door, three from the CD — and 0/10/∞ on the fees.

Recap

Application = six items; LE within 3 business days
7-business-day wait after LE; CD received 3 business days before closing
Mail = received in 3 business days
New CD wait only for APR tolerance, product change, prepayment penalty
Tolerances: 0% lender fees, 10% aggregate list-shopped, unlimited off-list/prepaids
Cures refunded at or within 60 days of closing