The document provides a quick reference to the TRID (TILA-RESPA Integrated Disclosure) rule for mortgage disclosures in the United States. It outlines that TRID applies to consumer purpose loans secured by real estate. It discusses the timing requirements for providing the Loan Estimate and Closing Disclosure to borrowers. It also defines what constitutes a "valid change circumstance" that allows lenders to issue revised disclosures outside of the standard timing rules. Finally, it reviews the different tolerance levels that apply to estimating settlement costs, taxes, and other fees on the Closing Disclosure form compared to what was previously disclosed on the Loan Estimate.
1. TRID Quick Reference by D Spurrier 2019
TRID
Applicable:
consumer purpose
closed end products AND
secured by real estate (dirt).
Timing of Loan Estimate (LE) and Closing Disclosure (CD):
Form Timing
Loan Estimate (LE) Within 3 business days of application
Revised Loan Estimate (see Valid Chg circumstance) Within 3 business days of being aware of a valid
change circumstance. A revised LE cannot be
issued if CD has already been issued.
Closing Disclosure (CD) Within 3 business days prior to consummation
Revised Closing Disclosure (see Valid Chg circumstance CD) If valid change circumstance exists initial or
revised CD can reset tolerances regardless of
number of days remaining prior to
consummation. After consummation, can be
given up to 30 days of identified valid chg.
circumstance.
If disclosures are not in person assume receipt 3 business days later.
*Business day is when bank is open to conduct substantially all of it’s services.
Application sufficient for TRID is obtaining the following information:
Consumer Name
Social Security number
Income
Property address
Estimate property value
Amount of loan desired
Valid Change Circumstance:
Revision of Form Circumstance
Loan Estimate When:
Change in circumstance relates to a increase in
settlement charges beyond tolerance variation
Consumer’s eligibility for loan or value of property
securing loan is affected
Consumer request for change in credit terms or
settlement and causes the estimate to increase
Interest rate lock
Expiration of loan estimate Intent to proceed is more
than 10 business days
Construction loan settlement delays
Closing Disclosure When:
APR inaccurate by more than 1/8th
Product change
Prepayment penalty added
2. TRID Quick Reference by D Spurrier 2019
Other changes then revise disclosure at closing but no
additional 3 business days
Tolerance of Total Payments not to be overstated or understated by $100. This tolerance is similar to
the tolerance on finance charges.
Settlement Section:
Tolerance Levels Meaning
Zero tolerance Cannot increase fee disclosed, unless due to triggering
event which requires revised loan estimate.
These fees are fees paid to the creditor or creditor has
access to actual fee ( required services which borrower
cannot shop for) and taxes based on loan amount or
sales price.
10% tolerance Cannot have a 10% cumulative increase
These fees are recording fees for documents and
required services which borrower can shop for and picks
from the Written List of Service providers.
No tolerance Unlimited or no tolerance placed on this category of
fees.
These fees creditor has little control over.
Section A Section B Section C
Origination Charges Services Borrower Did Not Shop For Services Borrower Did Shop For *
Zero Tolerance Zero Toleance 10% Tolerance
% of Loan Amt (Points)
Application fee
Appraisal fee
Credit Report fee
Flood Determination fee
Inspection fee
Survey fee
Title – Closing agent fee
Title – Exam/Search/Insurance
fee
* If LE indicates consumer selects from
Written List of Service Providers then
items should be reflected on Closing
Disclosure as Services Borrower Did
Not Shop For.
* If LE indicates consumer selects
provider not on Written list then
Closing Disclosure would continue to
reflect Services Borrower Did Shop For
but as No Tolerance.
Section E Section F Section G
Taxes and Other Government Fees Prepaids Initial Escrow Payment at Closing
10% Tolerance No Tolerance No Tolerance
Recording Fees
Doc Stamps (Zero
tolerance)
Homeowner’s Insurance
premium
Mortgage Insurance
premium
Prepaid interest
Homeowner’s Insurance
Mortgage Insurance
Property Tax
Flood Insurance
3. TRID Quick Reference by D Spurrier 2019
Property Tax
Section H
Other
No Tolerance
Title – Owner’s insurance policy