Currently, when disclosures are sent late, the comparison table on page 3 of the HUD-1 must show all zeros in the GFE column to compare and calculate the out of tolerance.
With TRID, if disclosures are sent late, are we to put Zeros in the closing cost sections of the Loan Estimate column on page 3 of the Closing Disclosure?
There may be more guidance on this later, but as far as I know, there is nothing in the regulation or commentary that specifically addresses this. The regulation does say that you must disclose what was disclosed on the LE. Based on that I would say you should disclose the amounts you disclosed on the LE then, if deemed necessary, factor in $0 for those fee amounts from the loan estimate when you are doing the side calculation to determine tolerance.