TRID: Loan Estimate and Closing Disclosure timing

Bottom line: TRID is the federal rulebook that makes lenders show the same numbers in a standard format at two moments: early (Loan Estimate) and just before closing (Closing Disclosure). The lender, not the broker, issues them. You still need the timing, because a missed deadline can move the closing date you promised your client.

What TRID is

TRID stands for the TILA-RESPA Integrated Disclosure rule. It joins two older laws: TILA (Truth in Lending Act, about loan cost) and RESPA (Real Estate Settlement Procedures Act, about settlement costs). The rule text is in Regulation Z, 12 C.F.R. 1026.19(e) and (f), with the form contents in 1026.37 and 1026.38. It covers most closed-end mortgage loans on homes. It does not cover a cash purchase, a home equity line of credit, or a reverse mortgage. The creditor (the lender) is responsible for the forms.

Loan Estimate

A Loan Estimate (LE) is a three-page form that shows the loan terms and estimated costs. The lender must deliver or mail it no later than 3 business days after receiving the borrower's application (12 C.F.R. 1026.19(e)(1)(iii)). An application exists when the lender has six facts: the borrower's name, income, Social Security number, the property address, an estimate of the property value, and the loan amount. For the LE, a "business day" is any day the lender's offices are open for business activities. The lender may not charge fees (except a credit report fee) until the borrower has received the LE and says to go ahead.

A revised LE can be issued when something valid changes, such as a rate lock or a change the borrower asks for. The borrower must receive any revised LE at least 4 business days before closing.

Closing Disclosure

The Closing Disclosure (CD) is a five-page form with the final loan terms and every cost. The borrower must receive it at least 3 business days before consummation (12 C.F.R. 1026.19(f)(1)(ii)). Consummation means the day the borrower becomes legally bound to the loan, usually signing day. For this 3-day count, a business day is every calendar day except Sundays and federal legal holidays, so a Saturday counts. If the CD is mailed, it is treated as received 3 business days after it is mailed (unless there is proof of earlier receipt). Email counts only if the borrower agreed to electronic delivery first.

The seller's side is shown on a separate seller Closing Disclosure (or on the combined one) given by the closing agent. The lender gives the buyer's CD; the settlement agent commonly handles delivery for both. The broker does not issue either form, and Commission Rule 6.21 forbids brokers to take referral fees tied to a federally related mortgage except as RESPA allows. A broker should review the numbers against the contract (Rule 6.19.C).

Changes that restart the 3-day wait

If the CD changes after delivery, the lender usually gives a corrected CD at or before closing and closing can go ahead. But three changes require a new CD and a fresh 3-business-day wait (12 C.F.R. 1026.19(f)(2)(ii)):

1. The APR (annual percentage rate, the yearly cost of the loan including some fees) becomes inaccurate beyond the limit. For a regular fixed or adjustable loan the limit is one-eighth of one percentage point (0.125). Example: disclosed APR 6.500%, new APR 6.640%: the rise is 0.140, which is more than 0.125, so the wait restarts. A rise to 6.610% is 0.110, inside the limit.
2. The loan product changes, such as fixed rate to adjustable rate.
3. A prepayment penalty (a fee for paying the loan off early) is added.

Other changes (a small cost fix, a change of a seller credit) need a corrected CD but not a new waiting period. Tip: if a rate-lock expires or a loan changes in the last week, tell your client the closing day may slip and check the contract's closing deadline and extension options.

Tolerance: how much can estimates rise?

Tolerance is how far a final charge may exceed the LE number before the lender must pay the difference (a cure). There are three buckets (12 C.F.R. 1026.19(e)(3)):

• Zero tolerance: cannot go up at all. Includes the lender's own fees (origination charge), fees paid to the lender's affiliates, transfer taxes, and any fee for a service the borrower was not allowed to shop for.
• 10% tolerance: the total of the bucket may rise up to 10%. Includes recording fees and third-party services the borrower could shop for and chose from the lender's list.
• No limit (unlimited): may change, but estimates must be made in good faith. Includes prepaid interest, homeowner's insurance premiums, escrow deposits, and services the borrower shopped for and chose off the list.

Example with real numbers

A Boulder County buyer applies on Monday, March 2, 2026. The lender must deliver the LE by Thursday, March 5 (3 business days). The LE shows: origination charge $4,200 (zero bucket); recording $120 plus shopped title services $880 = $1,000 (10% bucket).

• Zero bucket: the CD shows origination $4,500. The lender must refund 4,500 - 4,200 = $300.
• 10% bucket: the limit is 1,000 x 1.10 = $1,100. The CD shows $1,180. Overage: 1,180 - 1,100 = $80. The lender must refund the $80 that exceeds the limit, not the $180 total rise.

Timing: closing is Friday, March 27. The borrower must receive the CD by Monday, March 23. Count: Tue 24 (1), Wed 25 (2), Thu 26 (3), closing Fri 27. If the lender mails it on Monday, March 23, it is deemed received Thursday, March 26 (3 business days later: Tue, Wed, Thu). The earliest closing is then three business days after that: Fri 27 (1), Sat 28 (2), Mon 30 (3, because Sunday March 29 is skipped), so Tuesday, March 31.

Now suppose on Wednesday, March 25, the lender changes the loan from fixed to adjustable. That is a product change, so a new CD must be received and the wait restarts: if received March 25, the earliest closing is Mon, March 30 (Thu 26, Fri 27, Sat 28 = 3 days, so the next day Sunday is skipped to Monday). Your client's contract closing date must move, so you check the extension deadline right away.

What brokers should and should not do

Do tell clients to deliver documents to the lender promptly so the LE and CD are not delayed. Do not tell a client what a loan will cost as a guarantee: only the lender's LE and CD give disclosed numbers. Do not accept payment from a lender or title company for sending business to it (Rule 6.21).