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Thank you for the Knoxville TRID presentation! I had a question regarding the signature of receipt for the Closing Disclosure. We typically mail these out 6-days prior to closing and make a copy of the postage envelope for the file. The customer may or may not bring the CD back with them but we have a copy. Do they sign the CD that they received it the day of closing or the day that they say they received it in the mail? Thanks!
Even with the most honest intentions (e.g. disclosure was delivered earlier) I don’t like back-dating disclosures. The date should reflect the date it is signed. Your file and procedures should show that you delivered the CD in the required timeframe. Ensure your written procedures reflect how you will handle CDs that are mailed, including documenting the file to show the date the disclosure was mailed, and how you will handle signatures, such as the disclosure will be signed at closing. Make sure these procedures are carried through and reflected in the loan file as evidence of delivery.
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