A mortgage file is paused during a secondary-market screen because of TILA TRID Disclosures. Which answer should select the answer that fits the governing requirement?
Correct Answer
C) 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 loan 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, or at the consumer's request. Using a revised estimate without a valid reason is a violation. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because TRID's timing and content rules are federal mandates that cannot be overridden by internal policy. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because TRID disclosures must be provided to the consumer promptly, not withheld until an audit. "Resolve the TILA TRID Disclosures issue with the SAFE Act testing exception that does not fit the facts" is wrong because the SAFE Act (licensing) is unrelated to TRID disclosure requirements. Exam tip: A revised Loan Estimate is not allowed for minor reasons. Valid reasons are limited (e.g., changed circumstance, interest rate lock, consumer request).
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 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: Resolve the TILA TRID Disclosures issue with the SAFE Act testing exception that does not fit the facts.
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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