For a covered TRID transaction, a $220 excess under section 1026.19(e)(3)(i) or (ii) is discovered 21 days after consummation. What is the deadline under section 1026.19(f)(2)(v) to refund the excess and deliver or mail a Closing Disclosure reflecting that refund?
Correct Answer
C) No later than 60 days after consummation: refund $220 and deliver or mail the corrected disclosure
C. Complete both required cure actions by day 60 after consummation. The clock starts at consummation, not discovery. Discovery on day 21 leaves 39 days until the stated day-60 deadline. Scope and exceptions: The rule permits delivering or placing the corrected disclosure in the mail by the deadline; it does not require receipt by day 60. This specific tolerance cure is not a universal deadline or cure for every closing error. Source: Section 1026.19(f)(2)(v) and comment 19(f)(2)(v)-1 — https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
Why This Is the Correct Answer
C. Complete both required cure actions by day 60 after consummation. The clock starts at consummation, not discovery. Discovery on day 21 leaves 39 days until the stated day-60 deadline. Scope and exceptions: The rule permits delivering or placing the corrected disclosure in the mail by the deadline; it does not require receipt by day 60. This specific tolerance cure is not a universal deadline or cure for every closing error.
Why the Other Options Are Wrong
Option A: Within 30 days of consummation, after which no cure is available
Day 30 would be early, but is not the statutory deadline for this cure.
Option B: Within 90 days of consummation, matching the general correction window
The provision does not allow 90 days.
Option D: At any time, provided the borrower has not already filed a complaint
Absence of a complaint does not extend the deadline.
Exam Tip
Track the original trigger and both required actions.
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