What is TRID compliance?

TRID (Truth in Lending Act-Real Estate Settlement Procedures Act Integrated Disclosure) compliance requires lenders to provide accurate, timely disclosures including the Loan Estimate within 3 business days of application and Closing Disclosure at least 3 business days before consummation.

When must the Loan Estimate be provided under TRID?

The Loan Estimate must be delivered or mailed within 3 business days of receiving a complete application containing the six required pieces of information: Property address, Estimated property value, Consumer name, Consumer SSN, Income, and Loan amount (PENCIL).

What is the 3-day Closing Disclosure rule?

Under TRID, consumers must receive the Closing Disclosure at least 3 business days before loan consummation. This uses the specific business day definition (Monday through Saturday, except federal holidays) and allows consumers time to review final loan terms.

What triggers a new 3-day waiting period under TRID?

A new 3-day waiting period is required if the APR becomes inaccurate, loan product information changes, or a prepayment penalty is added after the initial Closing Disclosure is provided.

What are TRID business day definitions?

TRID uses two business day definitions: Standard (days when creditor's offices are open for substantially all business functions) for most deadlines, and Specific (Monday through Saturday except federal holidays) for the Closing Disclosure 3-day rule.

What are changed circumstances under TRID?

Changed circumstances include events affecting borrower eligibility, settlement charges, or property value that occur after the Loan Estimate is provided. Lenders must provide revised estimates within 3 business days when these circumstances change.

What are the penalties for TRID violations?

TRID violations can result in regulatory penalties, potential rescission rights for consumers, fee tolerance violations, and enforcement actions by the CFPB. Violations may also affect loan saleability to government-sponsored enterprises.

TRID Compliance Timeline

Know Your Before You Owe timeline and requirements - comprehensive guide to TRID compliance deadlines.

📅 Business Day Definitions

Standard Definition

Days when the creditor's offices are open for substantially all business functions

(varies by institution)

Specific Definition

Monday through Saturday, except federal holidays

(consistent across all institutions)

Note: The specific definition is used for certain TRID timing requirements, particularly the 3-day Closing Disclosure rule.

Calculate Your Timeline

Application Date

TRID Timeline Events

Application Received

CRITICALDay 0Standard Days

Consumer submits complete mortgage application with all six required pieces of information (PENCIL).

Key Requirements:

Property Address
Estimated Value of Property
Name of Consumer
Consumer's SSN
Income
Loan Amount

Loan Estimate Due

CRITICALWithin 3 business daysStandard Days

Lender must deliver or mail the Loan Estimate within 3 business days of receiving the complete application.

Key Requirements:

Use standard business day definition
No fees allowed before providing LE (except credit report fee)
Applies to pre-approval/pre-qualification applications
Can be delivered by creditor or mortgage broker

Compliance Risk:

TRID violation - regulatory penalties and potential rescission rights

Intent to Proceed

HIGHAfter Loan EstimateStandard Days

Consumer must indicate intent to proceed before lender can order appraisal or charge additional fees.

Key Requirements:

Required before appraisal can be ordered
Can be verbal, written, or electronic
No specific timeframe required
Protects consumer from unnecessary fees

Changed Circumstances

HIGHWithin 3 business days of changeStandard Days

When circumstances change affecting eligibility, settlement charges, or property value, revised Loan Estimate may be required.

Key Requirements:

Changed circumstances affecting eligibility
Changed circumstances affecting settlement charges
Changed circumstances affecting property value
Revisions requested by consumer
Interest rate lock expires
Construction loan delays (60+ days)

Compliance Risk:

Fee tolerance violations and potential regulatory action

7 Business Days Before Closing

MEDIUM7 business days before consummationStandard Days

Latest point when original Loan Estimate can be provided and still meet closing timeline.

Key Requirements:

Original Loan Estimate must be received 7 business days before consummation
Revised Loan Estimates can be provided up to 4 business days before closing
Cannot provide revised LE on or after CD is issued

Closing Disclosure Required

CRITICAL3 business days before closingSpecific Days

Consumer must receive Closing Disclosure at least 3 business days before loan consummation.

Key Requirements:

Uses specific business day definition (Mon-Sat, except federal holidays)
If mailed, consumer presumed to receive 3 business days after mailing
Must contain final, accurate loan terms and costs
Can be provided by settlement agent on lender's behalf

Compliance Risk:

New 3-day waiting period required for certain changes

Closing Day

CRITICALAfter all waiting periodsSpecific Days

Loan consummation can occur after all timing requirements have been satisfied.

Key Requirements:

Confirm all 3-day periods have elapsed
Verify no changes requiring new disclosure
Ensure borrower has had opportunity to review final terms
Complete loan documentation and funding

🚨 New 3-Day Period Triggers

If these changes occur after the initial Closing Disclosure, a new 3-day waiting period is required:

APR becomes inaccurate

Loan product information changes

Prepayment penalty added

💡 Key Compliance Points

Good Faith Standard

All disclosed fees must be provided in good faith and within tolerance thresholds. Zero tolerance for lender/broker fees, 10% cumulative tolerance for third-party services.

Record Retention

Keep Loan Estimates for 3+ years, Closing Disclosures for 5+ years. Proper documentation is essential for examinations.

Black Hole Period

The gap between 3-day LE revision window and 4-day CD pre-consummation window has been addressed by recent rule changes.

Model Forms

Using CFPB model forms provides safe harbor protection when properly completed with accurate content.

Download Complete Timeline

Get the comprehensive TRID Compliance Timeline as a PDF for easy reference, printing, and team sharing.

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Complete TRID Compliance Guide for Mortgage Professionals

The Truth in Lending Act-Real Estate Settlement Procedures Act Integrated Disclosure (TRID) rule, also known as the "Know Before You Owe" rule, fundamentally changed mortgage disclosure requirements. This comprehensive timeline ensures compliance with all CFPB requirements and helps prevent costly violations.

TRID Timeline Requirements and Critical Deadlines

TRID compliance begins when a complete application is received containing all six required elements (PENCIL): Property address, Estimated property value, Consumer name, Consumer Social Security Number, Income, and Loan amount. The Loan Estimate must be delivered within 3 business days using the standard business day definition.

Loan Estimate Delivery and Timing Requirements

The Loan Estimate serves as the primary disclosure document and must be provided before collecting most fees (except credit report fees). Lenders cannot charge application fees, origination fees, or order appraisals until the consumer receives the Loan Estimate and indicates intent to proceed.

Business Day Definitions Under TRID

TRID employs two distinct business day definitions. The standard definition varies by institution and covers days when the creditor's offices are open for substantially all business functions. The specific definition consistently applies Monday through Saturday, excluding federal holidays, and is used specifically for the Closing Disclosure 3-day rule.

Changed Circumstances and Revised Disclosures

When circumstances change affecting borrower eligibility, settlement charges exceeding tolerance thresholds, or property value, lenders must provide revised Loan Estimates within 3 business days. Changed circumstances include borrower-requested changes, interest rate lock expirations, and construction loan delays exceeding 60 days.

Closing Disclosure Requirements and 3-Day Rule

The Closing Disclosure must be provided at least 3 business days before loan consummation using the specific business day definition. If mailed, consumers are presumed to receive the disclosure 3 business days after mailing unless evidence proves earlier receipt.

New Waiting Period Triggers

Certain changes after Closing Disclosure delivery trigger new 3-day waiting periods: APR changes making the disclosed APR inaccurate, loan product changes, and addition of prepayment penalties. These changes require corrected disclosures and reset timing requirements.

Fee Tolerance and Good Faith Requirements

TRID establishes strict fee tolerance standards. Zero tolerance applies to lender and mortgage broker charges, affiliate fees, and transfer taxes. Ten percent cumulative tolerance applies to third-party services where borrowers can shop for providers. Unlimited tolerance applies to services where borrowers cannot shop.

Compliance Best Practices and Risk Management

Successful TRID compliance requires systematic processes for application tracking, business day calculations, disclosure delivery confirmation, changed circumstances monitoring, and comprehensive record retention. Model forms provide safe harbor protection when properly completed with accurate information.

Record Retention and Documentation

Maintain Loan Estimates for minimum 3 years and Closing Disclosures for minimum 5 years. Document delivery methods, timing calculations, and changed circumstances decisions. Proper documentation is essential for regulatory examinations and compliance validation.

Integration with Transaction Coordination

Transaction coordinators play crucial roles in TRID compliance by monitoring disclosure deadlines, coordinating with lenders on timing requirements, tracking changed circumstances, and ensuring all parties understand timing constraints affecting closing schedules.