TRID APPLICABILITY AND TIMELINE
By Dennis Doss
- Is your borrower a bona fide business entity? If yes, TRID does not apply to loans to business entities and you may stop here.
- Is your collateral a 1-4 residential property? If no, TRID only applies to residential loans and you may stop here. If yes, proceed to the next question.
- Is the primary purpose of the loan personal, family or household? If no, TRID does not apply to business purpose loans and you can stop here. If Yes, TRID applies.
- If TRID applies: *You must have an NMLS endorsement to your lending license. *A Loan Estimate must be sent within 3 business days of a loan application. If the loan is High Cost (Section 32) a HOEPA disclosure is also due. Other disclosures are typically given at this time as well, such a fair lending, state disclosure, appraisal disclosure, credit score disclosure. *Unless the borrower waives the early cooling off period to meet a bona fide personal financing emergency, you cannot close and record your loan until 7 business days after providing your Loan Estimate. *A final Closing Disclosure must be provided at least 3 business days before the signing of your final loan documents and closing. *If your loan is secured by the borrower’s principal dwelling a 3 day right to cancel must be given. *If your loan is High Cost (Section 32) a HUD counseling certificate is required before closing.