What this lesson covers
TRID, the TILA-RESPA Integrated Disclosure rule, gives a mortgage borrower two forms: the Loan Estimate soon after applying and the Closing Disclosure before closing. Most TRID questions are calendar questions: a document goes out on a given day, and you name the deadline or the earliest closing date. This free lesson teaches the four deadlines, the two kinds of business day, the mailbox rule and the few events that reset the clock, with every calendar counted twice.
The two kinds of business day
Regulation Z defines "business day" two ways (1026.2(a)(6)). Picking the right one is half of every timing question.
| Kind | Days that count | Used for |
|---|---|---|
| General | Days the creditor's offices are open to the public for substantially all business | The Loan Estimate due three business days after application; a revised Loan Estimate due three business days after the creditor learns the reason (including a rate lock) |
| Specific | Every day except Sundays and legal public holidays, so Saturdays count | The seven-day wait after the Loan Estimate, the four-day rule for a revised Loan Estimate, the three-day Closing Disclosure wait and the mailbox rule |
A simple way to remember it: deadlines that depend on the creditor doing work use the creditor's open days. Waits that protect the consumer use the specific definition.
How to count. The day something happens is day zero. Start counting on the next day.
What starts the clock
The Loan Estimate clock starts when the creditor has an application, which for TRID means six pieces of information (1026.2(a)(3)(ii)): the consumer's name, income, Social Security number, property address, an estimate of the property's value and the loan amount sought. A signed form, a sales contract or pay stubs are not needed to start it.
The four deadlines
| Document | Deadline | Verb | Business day |
|---|---|---|---|
| Loan Estimate | By the 3rd business day after application (1026.19(e)(1)(iii)(A)) | Delivered or mailed | General |
| Loan Estimate | At least 7 business days before consummation (1026.19(e)(1)(iii)(B)) | Delivered or mailed | Specific |
| Revised Loan Estimate | At least 4 business days before consummation (1026.19(e)(4)(ii)) | Received | Specific |
| Closing Disclosure | At least 3 business days before consummation (1026.19(f)(1)(ii)) | Received | Specific |
Consummation is the time the consumer becomes contractually obligated on the loan (1026.2(a)(13)). It is usually the signing, which may differ from the day funds move.
The mailbox rule. A disclosure that is not handed over in person, including one sent by mail or email, is treated as received three specific business days after it is delivered or mailed (1026.19(e)(1)(iv) for the Loan Estimate, 1026.19(f)(1)(iii) for the Closing Disclosure). The creditor may rely on proof of earlier receipt. The mailbox rule matters most for the two "received" deadlines.
Calendar 1: the first Loan Estimate
A lender open Monday to Friday has all six pieces of information on a Wednesday. When is the Loan Estimate due?
- General business days: Thursday 1, Friday 2, (Saturday and Sunday closed), Monday 3.
- The Loan Estimate must be delivered or placed in the mail by Monday.
Check: change one fact. If the same lender were open Saturdays for substantially all business, Saturday would be day 3 and the deadline would be Saturday. The lender's office days are the only thing that moved the answer.
Calendar 2: the seven-business-day wait
A Loan Estimate is emailed to the consumer on a Friday. Under the seven-day rule alone, what is the earliest consummation date?
- Specific business days: Saturday 1, (Sunday skipped), Monday 2, Tuesday 3, Wednesday 4, Thursday 5, Friday 6, Saturday 7.
- Consummation may happen as early as the following Saturday. If the parties do not close on Saturdays, the next choice is Monday.
Check: count back seven specific business days from that Saturday: Friday, Thursday, Wednesday, Tuesday, Monday, Saturday, Friday. The seventh is the Friday the Loan Estimate was sent. The seven days run from delivery or mailing, so email does not add the mailbox days here.
Calendar 3: a Closing Disclosure handed over in person
The consumer receives the Closing Disclosure in person on a Wednesday, and nothing changes afterward. What is the earliest consummation date?
- Specific business days: Thursday 1, Friday 2, Saturday 3.
- The rule allows consummation on Saturday. If the parties do not close on Saturdays, the next choice is Monday.
Check: count back three specific business days from Saturday: Friday, Thursday, Wednesday. Wednesday is the day of receipt, so Saturday works.
Calendar 4: a Closing Disclosure sent by mail
The creditor mails the Closing Disclosure on a Thursday and has no proof of earlier receipt. What is the earliest consummation date?
- Deemed received three specific business days after mailing: Friday 1, Saturday 2, Monday 3.
- Then three specific business days after receipt: Tuesday 1, Wednesday 2, Thursday 3.
- Earliest consummation: the next Thursday, one week after mailing.
Check: mailing adds three days and the wait adds three more, so consummation can be on the sixth specific business day after mailing: Friday, Saturday, Monday, Tuesday, Wednesday, Thursday. Same answer.
Calendar 5: a revised Loan Estimate and the Closing Disclosure together
The borrower asks to change the loan amount, and consummation is set for a Tuesday. What is the latest the borrower can receive the revised Loan Estimate, and the latest to receive the Closing Disclosure?
- Revised Loan Estimate, received at least four specific business days before: Monday, Saturday, Friday, Thursday (the week before).
- Closing Disclosure, received at least three specific business days before: Monday, Saturday, Friday.
- The revised Loan Estimate may not be given on or after the day the Closing Disclosure is given (1026.19(e)(4)(ii)). Revised Loan Estimate in person on Thursday, Closing Disclosure in person on Friday, meets every rule.
Check: count forward. From Thursday: Friday 1, Saturday 2, Monday 3, Tuesday 4. From Friday: Saturday 1, Monday 2, Tuesday 3. If the revised Loan Estimate were mailed instead, it would have to go out by the Monday before (Tuesday 1, Wednesday 2, Thursday 3) to be deemed received Thursday.
Calendar 6: a rate lock
A lender open Monday to Friday gave a Loan Estimate with a floating rate. The borrower locks on a Friday. When is the revised Loan Estimate due?
- The revised Loan Estimate is due within three business days after the lock (1026.19(e)(3)(iv)(D)), counted in the lender's open days: Monday 1, Tuesday 2, Wednesday 3.
Check: Saturday and Sunday are not general business days for a lender closed on weekends, so neither counts. Counting them by mistake would give Monday, two days too early.
What resets the clock after the Closing Disclosure
Most changes after the consumer receives the Closing Disclosure need only a corrected Closing Disclosure at or before consummation, with no new wait (1026.19(f)(2)(i)). Only three changes require a corrected Closing Disclosure and a new three-business-day wait (1026.19(f)(2)(ii)):
- The APR becomes inaccurate beyond the tolerance in 1026.22 (1/8 of 1 percentage point on a regular transaction).
- The loan product changes, for example from a fixed rate to an adjustable rate.
- A prepayment penalty is added.
| Change after the Closing Disclosure | New 3-day wait? |
|---|---|
| Settlement agent's fee rises $150 | No: corrected Closing Disclosure at or before consummation |
| The rate is cut and the APR changes within the tolerance | No |
| A 30-year fixed becomes a 5/1 ARM | Yes: product change |
| The note adds a prepayment penalty | Yes |
| The APR rises beyond the tolerance | Yes |
Other timing rules on the same questions
- Fees before intent to proceed. No one may charge a fee, other than a bona fide and reasonable credit report fee, until the consumer has received the Loan Estimate and indicated an intent to proceed (1026.19(e)(2)(i)). Receiving the form is not enough on its own.
- Expiration. If the consumer indicates an intent to proceed more than 10 business days after the Loan Estimate was provided, or after any longer period the creditor set, the creditor may issue a revised Loan Estimate (1026.19(e)(3)(iv)(E)).
- Revisions in general. A revised Loan Estimate goes out within three business days of the creditor receiving the information that justifies it (1026.19(e)(4)(i)).
- Waiving a wait. The seven-day and three-day waits may be shortened or waived only for a bona fide personal financial emergency, after the consumer receives the disclosure, by a dated written statement that describes the emergency, specifically waives or modifies the wait and is signed by every consumer primarily liable. Printed forms are prohibited (1026.19(e)(1)(v) and (f)(1)(iv)).
Common traps
- Delivered versus received. The Loan Estimate deadlines use "delivered or mailed." The revised Loan Estimate and the Closing Disclosure must be received, so the mailbox rule can add three days.
- Saturday. It counts for every wait and for the mailbox rule, even if the lender is closed. It counts for the three-day Loan Estimate deadline only if the lender is open that day.
- Counting the starting day. The day of delivery, mailing or application is day zero.
- Thinking every change restarts the wait. Only an inaccurate APR, a product change or an added prepayment penalty does.
- Same-day revised Loan Estimate and Closing Disclosure. Not allowed.
- Charging an appraisal fee too early. Only the credit report fee may come before the intent to proceed.
How to work any timing question
- Which document? Loan Estimate, revised Loan Estimate or Closing Disclosure.
- Which deadline and verb? Three after application, seven before consummation (delivered or mailed); four or three before consummation (received).
- Which business day? General for the creditor's work, specific for the waits and the mailbox rule.
- How was it sent? In person means received that day; mail or email adds three specific business days.
- Count forward, then count back to check.
Try it
The ten free practice questions that go with this lesson use the same rules with different days. Write the days out in a row on your wipe board, mark Sundays, and count twice.
This lesson is study material for a licensing test, not legal advice.
Not affiliated with or endorsed by NMLS, CSBS or Prometric.