A team member asks about TILA Closing Disclosure Timing in an investor-delivery review while trying to identify which rule controls the file. Which response should the file reviewer use?

Correct Answer

D) Use a corrected Closing Disclosure when terms change

Why this is correct: The governing concept is the TILA-RESPA Integrated Disclosure (TRID) rule under Regulation Z. It requires that the Closing Disclosure be provided to the consumer at least three business days before consummation. Crucially, if a triggering event occurs that changes terms before closing, the creditor must provide a corrected Closing Disclosure and, if necessary, a new three-business-day waiting period. The correct answer, "Use a corrected Closing Disclosure when terms change," directly applies this rule to the file review scenario. Why the other choices are wrong: The choice "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because internal policies cannot override mandatory federal disclosure requirements. The choice "Wait until a regulator asks for the file before applying the federal requirement" is wrong because compliance with timing rules is required at the time of the transaction, not retroactively upon inquiry. The choice "Assume the TILA Closing Disclosure Timing condition is met because the borrower satisfied the separate refinance benefit requirement" is wrong because the timing requirement for the Closing Disclosure is a separate, independent legal obligation that is not satisfied by meeting other loan criteria. Exam tip: Remember the core TRID sequence: Loan Estimate, then Closing Disclosure. Any "valid change in circumstance" or other triggering event after the initial Closing Disclosure is issued requires a corrected disclosure and may reset the waiting period.