[Sandy]

I have a question about Trid documents and the timing by e-sign. If we e-sign our preliminary disclosures on the 3rd business day to the borrower but they do not open and e-sign them until after that 3rd day, are we in compliance since we sent them in the required 3 business days? Also, If we e-sign the closing disclosure 3 business days before the closing date but the borrower does not open and e-sign it on the 2nd business days are we still in compliance because we did send it within the 3 business days? Further, when they signed it 2 days before closing do we have to extend the closing date by 1 more day? I was concerned also if this would change the right of recission date.

Topic

[Kimberly Boatwright, CAMS, CRCM]

TRID timing requirements:
1. The LE is required to leave the lending institution on the third business day, following the “General Rule”. There is no requirement to prove the borrower reviewed the LE.
2. Closing disclosure – the lending institution must prove the borrow reviewed them three business days prior to closing, following the “Specific Rule” If they do not acknowledge receipt three days before closing you will have to extend the closing date.

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