SAFE MLO test · Timelines · Episode 2
Every TRID Deadline on One Calendar
Chapters
- Three days
- Application
- Loan Estimate
- Closing Disclosure
- Rescission
- Recap
In short
The Loan Estimate must be delivered or mailed within three general business days of the application, counting only days the lender is open. Every other TRID clock uses specific business days, every day except Sundays and federal holidays: closing waits seven of them after the Loan Estimate goes out, and three after the borrower receives the Closing Disclosure. Rescission on a refinance also runs three specific business days.
- An application exists once the lender has six items: name, income, SSN, property address, estimated value and loan amount.
- Loan Estimate: three general business days (days the lender is open).
- No closing until the seventh specific business day after the Loan Estimate, and the third after the Closing Disclosure is received.
- A new APR outside tolerance, a new loan product or an added prepayment penalty restarts the three-day wait.
Transcript
Three days
Most TRID deadlines say three business days. But they do not all count the same days. Here is every one, on one calendar.
Application
The clock starts with an application: six pieces of information. Name, income, Social Security number, property address, estimated value, and the loan amount. Once the lender has all six, the application exists, even if it wants more documents.
Loan Estimate
First deadline: the Loan Estimate goes out within three business days. Here, a business day is a day the lender is open for business. This lender is closed on Saturdays. Application on Friday the 2nd. Monday, Tuesday, Wednesday. It must be delivered or mailed by Wednesday the 7th. Second: no closing until the seventh business day after the Loan Estimate goes out. Now the definition changes. Every day counts except Sundays and federal holidays. Saturday counts. Sunday and Columbus Day do not. Day seven lands on Friday the 16th, the earliest the loan can close. A revised Loan Estimate must reach the borrower at least four business days before closing.
Closing Disclosure
Third: the Closing Disclosure must be received three business days before closing. Pause. The borrower has it on Tuesday the 10th, and Wednesday is Veterans Day. When is the earliest closing? Saturday the 14th. The holiday is skipped. Thursday, Friday and Saturday count. If it was mailed instead, the borrower is treated as receiving it three business days after mailing. Three changes restart the wait: an APR that is no longer accurate, a new loan product, or an added prepayment penalty. Anything else gets a corrected Closing Disclosure at closing, with no new wait.
Rescission
One more clock, and it is not TRID. On a refinance of the borrower's home, the right to rescind lasts three business days. It runs to midnight of the third business day after the last of three things: closing, the rescission notice, and the material disclosures. Same rule: Saturday counts, Sundays and holidays do not.
Recap
Five clocks. Only the first one counts the days the lender is open. Next: six consumer laws, one table. Subscribe so you catch it.
Sources
- 12 CFR 1026.2(a)(3)(ii) and 1026.2(a)(6)
- 12 CFR 1026.19(e) and (f)
- 12 CFR 1026.23(a)(3)
Independent study material. EstatePass is not affiliated with NMLS or CSBS, and nothing here is legal advice. Any lenders and borrowers in our episodes are fictional.