TRID Closing Disclosure Timing and Delivery

The primary borrower on purchase money transactions, and each borrower and each party on title on refinance transactions, must receive the Closing Disclosure no later than three (3) Business days before consummation (signing of the loan documents). If a settlement is scheduled during the 3-business day waiting period, the lender generally must postpone settlement.

To help identify when the closing disclosure must be delivered to all parties to the transaction, as applicable, to meet a specific closing date please refer to this helpful chart.

How to Count 3-Business Days BEFORE Consummation

 

Meeting the timing requirements of a Closing Disclosure is of utmost importance, not only to clients, but to those in the mortgage industry as well. Failure to comply with the timing regulations could lead to delay in closing, penalties, buy backs, as well as the potential loss of business. Therefore, all stakeholders in the mortgage loan process, such as loan originators and loan processors, need to be well versed in every single aspect of the loan to ensure that the Closing Disclosure is issued within the correct time frame to ensure that the closing takes place on the assigned day. The better prepared everyone is, the happier everyone will be.

 

Below are some examples to help you understand the timing of disclosures in relation to closing dates:

 

Example 1:

Closing date: Thursday

Delivery method: Hand delivered Is there a Federal holiday?: No Delivery date: Preceding Monday

Example 2:

Closing date: Thursday Delivery method: Mailed

Is there a Federal holiday?: No Delivery date: Preceding Thursday

Example 3:

Closing date: Thursday Delivery method: Mailed

Is there a Federal holiday?: Yes Delivery date: Preceding Wednesday

Example 4:

Closing date: Thursday Delivery method: E-sign

Is there a Federal holiday?: No

Delivery date: Preceding Wednesday, however

 

once evidence is received that each borrower and each party of title, if a refinance, has received the closing disclosure, the closing date may be moved up