An originator holds off recording an application as received until the borrower supplies bank statements and a pay stub, neither of which is one of the six items. What is the effect on the timing?
Correct Answer
C) Count timing from the application trigger
Why this is correct: Under TRID, the timing for providing the Loan Estimate is calculated from the point the "application" is received. The rule defines an application as the submission of six specific pieces of information: the consumer's name, income, Social Security number, property address, estimate of property value, and loan amount sought. All disclosure deadlines, including the three-business-day rule for the Loan Estimate, are counted from this trigger event. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because the application trigger and subsequent timing are defined by Regulation Z; internal policies cannot alter this legal starting point. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because the timing rule must be applied at the time of the transaction to ensure the consumer receives disclosures when legally required. "Rely on oral agreement when the rule requires documented compliance" is wrong because the application is based on the receipt of specific written information; an oral discussion does not start the clock until the six pieces are received. Exam tip: The TRID application trigger is specific. Know the six pieces of information. The clock starts only when all six are received by the lender.
Why This Is the Correct Answer
The correct response is "Count timing from the application trigger" because TRID Loan Estimate duties begin when the application trigger is met.
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 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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