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An operations lead compares the file facts with TILA Closing Disclosure during an underwriting condition review. Which conclusion is accurate?

Correct Answer

C) Delay consummation until the corrected disclosure timing is met

Why this is correct: The core concept is that Regulation Z's TRID rules mandate strict timing for the Closing Disclosure. The consumer must receive the initial Closing Disclosure at least three business days before consummation (closing). If a change occurs that triggers a corrected disclosure, a new three-business-day waiting period generally applies before consummation can proceed. The original explanation anchors this by stating the disclosure must be "received in time and corrected." Therefore, the only compliant action when a timing error is found is to delay the closing until the corrected disclosure has been provided and the required waiting period has elapsed. Why the other choices are wrong: The choice "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because a lender's internal policy cannot override or create an exception to a mandatory federal rule like TILA's disclosure timing. The choice "Wait until a regulator asks for the file before applying the federal requirement" is wrong because compliance with TILA is proactive and mandatory; waiting for a regulator to find the error constitutes a violation. The choice "Rely on oral agreement when the rule requires documented compliance" is wrong because TILA and Regulation Z requirements for disclosures are strictly based on written documentation; oral agreements do not satisfy the legal requirement. Exam tip: Remember the core TRID timing rule: 3 business days from receipt of the initial Closing Disclosure to consummation. If a correction is needed, the clock often resets. The rule is absolute; no internal policy or oral agreement can waive it.

Answer Options
A
Use an internal exception instead of the required federal disclosure or timing rule.
B
Wait until a regulator asks for the file before applying the federal requirement.
C
Delay consummation until the corrected disclosure timing is met
D
Rely on oral agreement when the rule requires documented compliance.

Why This Is the Correct Answer

The correct response is "Delay consummation until the corrected disclosure timing is met" because The Closing Disclosure must be received in time and corrected under Regulation Z rules.

Why the Other Options Are Wrong

Option A: Use an internal exception instead of the required federal disclosure or timing rule.

Use an internal exception instead of the required federal disclosure or timing rule. is not correct because it does not apply the rule tested by this file scenario.

Option B: Wait until a regulator asks for the file before applying the federal requirement.

Wait until a regulator asks for the file before applying the federal requirement. is not correct because it does not apply the rule tested by this file scenario.

Option D: Rely on oral agreement when the rule requires documented compliance.

Rely on oral agreement when the rule requires documented compliance. is not correct because it does not apply the rule tested by this file scenario.

Memory Technique

TRID Closing Disclosure timing: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.

Exam Tip

Match the file facts to TRID Closing Disclosure timing; do not choose an exception or shortcut that skips the required rule.

Common Mistakes to Avoid

  • -Choosing an internal exception instead of the governing rule
  • -Treating preliminary or informal facts as a substitute for required documentation
  • -Answering from a familiar but unrelated mortgage topic
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