A compliance analyst is resolving TRID Loan Estimate Timing during a quality-control sample. Which action best fits the rule?
Correct Answer
B) Use a revised Loan Estimate only for a valid reason
Why this is correct: Under the TILA-RESPA Integrated Disclosure (TRID) rule, a Loan Estimate must be provided to the consumer within three business days of receiving a completed application. A creditor may issue a revised Loan Estimate only under specific, valid circumstances defined by the rule, such as a changed circumstance affecting settlement charges, a revised interest rate lock, or a consumer-requested change. The correct action is to "Use a revised Loan Estimate only for a valid reason." 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 the mandatory federal TRID timing and disclosure requirements. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because TRID deadlines are strict and must be met at origination, not deferred. "Rely on oral agreement when the rule requires documented compliance" is wrong because TRID disclosures must be provided in writing; oral agreements do not satisfy the rule. Exam tip: For TRID timing, think "3-7-3": 3 days for the Loan Estimate after application, and the Closing Disclosure 3 days before closing. Revised estimates are permitted only for specific, valid reasons.
Why This Is the Correct Answer
The correct response is "Use a revised Loan Estimate only for a valid reason" 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 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: 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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