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A risk reviewer compares the file facts with TRID Loan Estimate Timing during a new-hire scenario. Which conclusion is accurate?

Correct Answer

C) Collect only a bona fide credit-report fee before intent

Why this is correct: Under the TILA-RESPA Integrated Disclosure (TRID) rule, a creditor may collect only a bona fide and reasonable fee for obtaining a consumer's credit report before the consumer has received the Loan Estimate and indicated intent to proceed with the application. This fee is an exception to the general rule that fees cannot be collected before the consumer receives the Loan Estimate. Therefore, "Collect only a bona fide credit-report fee before intent" accurately reflects the TRID timing rule. Why the other choices are wrong: "Apply the correct general concept to the wrong closing disclosure stage rather than the TRID Loan Estimate Timing rule" is wrong because it misapplies a correct principle (e.g., fee collection timing) to the wrong disclosure (Closing Disclosure instead of Loan Estimate). "Wait until a regulator asks for the file before applying the federal requirement" is wrong because TRID timing rules are mandatory and proactive. "Rely on oral agreement when the rule requires documented compliance" is wrong because TRID requires specific written disclosures (Loan Estimate) to be provided. Exam tip: Remember the limited exception: only a credit report fee can be collected before the consumer receives the Loan Estimate and indicates intent.

Answer Options
A
Apply the correct general concept to the wrong closing disclosure stage rather than the TRID Loan Estimate Timing rule.
B
Wait until a regulator asks for the file before applying the federal requirement.
C
Collect only a bona fide credit-report fee before intent
D
Rely on oral agreement when the rule requires documented compliance.

Why This Is the Correct Answer

The correct response is "Collect only a bona fide credit-report fee before intent" because TRID Loan Estimate duties begin when the application trigger is met.

Why the Other Options Are Wrong

Option A: Apply the correct general concept to the wrong closing disclosure stage rather than the TRID Loan Estimate Timing rule.

This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.

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 Loan Estimate 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 Loan Estimate 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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