During a disclosure desk review, a processor encounters a TRID Loan Estimate Timing issue. Which response should select the answer that fits the governing requirement?
Correct Answer
A) Collect only a bona fide credit-report fee before intent
Why this is correct: Under TRID rules, a lender cannot charge a fee (except for a bona fide credit report fee) to a consumer before the consumer has received the Loan Estimate and indicated intent to proceed with the transaction. This protects consumers from being charged upfront without receiving required disclosures. Therefore, the compliant action is to collect only a bona fide credit-report fee before intent. 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 TRID's federal fee restriction. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because TRID compliance is mandatory and proactive. "Use prior changed-circumstance approval as a substitute for the current TRID Loan Estimate Timing requirement" is wrong because changed-circumstance rules relate to revised estimates, not the initial fee restriction. Exam tip: Before the consumer indicates intent, you can only charge for a credit report—any other fee violates TRID.
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 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: 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: Use prior changed-circumstance approval as a substitute for the current TRID Loan Estimate Timing requirement.
This distractor shifts the issue to a different trigger, product, or timing rule instead of applying the rule tested in the stem.
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
More Federal Laws Questions
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During a disclosure desk review, the loan team encounters an RESPA Servicing Transfer issue. Which response should avoid a shortcut that would misapply the rule?
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