A team member asks about TILA TRID Tolerances in a compliance desk review while trying to identify which rule controls the file. Which response should a disclosure specialist use?

Correct Answer

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

Why this is correct: Under TILA-RESPA Integrated Disclosure (TRID) rules, if there is a change in loan terms that causes the Loan Estimate to become invalid, a new waiting period may be required before closing. The rule specifies that this waiting period is restarted only for certain significant changes, which include an increase in the APR beyond permitted tolerances, a change in the loan product (e.g., from fixed-rate to adjustable-rate), or the addition of a prepayment penalty. The correct answer directly references these specific triggers, which is consistent with the original explanation's focus on correcting the Closing Disclosure under Regulation Z rules. 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 supersede federal TRID timing and tolerance requirements. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because compliance must be proactive and timely; waiting for a regulator is a failure to comply. "Rely on oral agreement when the rule requires documented compliance" is wrong because TRID disclosures and timing rules require written documentation; oral agreements are insufficient. Exam tip: Memorize the three triggers that restart the waiting period: changes to APR, loan product, or prepayment penalty. Other changes typically do not restart the clock.