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A mortgage file is paused during a lock-desk handoff because of TILA TRID Timing Requirements. Which answer should apply the requirement without relying on borrower preference?

Correct Answer

A) Restart the wait only for APR, product, or prepayment-penalty triggers

Why this is correct: The TILA TRID rule (Regulation Z) mandates that a Closing Disclosure be provided to the borrower at least three business days before consummation. If a change occurs that triggers a new waiting period, the rule specifies that the period restarts only for certain "valid" changes: an increase in the Annual Percentage Rate (APR), a change in loan product (e.g., from fixed-rate to adjustable-rate), or the addition of a prepayment penalty. The correct answer, "Restart the wait only for APR, product, or prepayment-penalty triggers," directly applies this federal requirement without introducing borrower preference, which is not a valid basis for restarting the clock under the rule. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because internal policies cannot override mandatory federal disclosure timing. "Treat the TILA TRID Timing Requirements review as complete because the file contains a related credit underwriting note" is wrong because a note does not satisfy the specific disclosure delivery and waiting period requirements. "Rely on oral agreement when the rule requires documented compliance" is wrong because TRID compliance requires proper written disclosures, not oral agreements. Exam tip: Remember the three specific triggers that restart the TRID waiting period: APR increase, product change, or adding a prepayment penalty. All other changes generally do not require a new waiting period.

Answer Options
A
Restart the wait only for APR, product, or prepayment-penalty triggers
B
Use an internal exception instead of the required federal disclosure or timing rule.
C
Treat the TILA TRID Timing Requirements review as complete because the file contains a related credit underwriting note.
D
Rely on oral agreement when the rule requires documented compliance.

Why This Is the Correct Answer

The correct response is "Restart the wait only for APR, product, or prepayment-penalty triggers" because The Closing Disclosure must be received in time and corrected under Regulation Z rules.

Why the Other Options Are Wrong

Option B: 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 C: Treat the TILA TRID Timing Requirements review as complete because the file contains a related credit underwriting note.

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

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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