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We sat through the TRID update webinar last week and this was one of the questions, but I need it in writing.
We keep hearing that other institutions are sending out a prelim cd to cover the 6 day waiting period. There is no set closing date at this time, it sounds like it is being sent out at clear to close. Then a new CD is being completed at the actual closing date. Is this something that we can do? We feel that we are the odd man out by not doing this and is hurting our customers, and reputation with realtors.
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Creditors are required to place a Closing Disclosure in the hands of a consumer no later than three business days (specific days) before closing. Mailing it six days before closing assures an appropriate result. This is the latest date the disclosure can be provided; it may provided sooner. The disclosure must be prepared based on the best information reasonably available on the date the disclosure is prepared.
If the initial CD changes after delivery a revised disclosure may be provided as late as the closing date unless the change causes the APR to be inaccurate, the loan product changes or a prepayment penalty is added. In any of these situations the consumer must receive the revised disclosure no later than three business days before consummation.
None of the above is new; it has been in effect since October 2015. It is not clear to us how this differs from your practice. Please explain.
what we are wanting to do is send out the CD at clear to close and attempt to have the closing on the 6th day. It may not always take place on that date but we will not know this the day we are sending out the CD. If the closing date differed we would then prepare a new CD at time of closing keeping in mind that we would have a 3 day wait period if the APR to be inaccurate, the loan product changes or a prepayment penalty is added. Due to odd days interest out APR and finance charges would differ from the original CD that was prepared but should not be off more than 1/8.
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