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June 19, 2016

Ken’s tips for the Closing Disclosure

Timing Changes to the Closing Process
Well, it’s bye bye time for the good old TIL and HUD. No longer will notaries be waiting for approval of the “final HUD”. Hooray. Borrowers will usually have the new Closing Statement 6 days prior to notary arrival! Less chance for a surprise at the table.
The changes to loan and closing procedures are far more than a few new documents. The biggest changes are to the closing time-lines.

The HUD-1 and Truth in Lending forms will be replaced by a new “Closing Disclosure.”

You will need to learn a new vocabulary. Some common terms are:
TRID = TILA/RESPA Integrated Disclosure
CD = Closing Disclosure
Consummation = Closing
CFPB = Consumer Finance Protection Bureau

Time Frames
New timing and delivery requirements will change the way we handle closings. This is the BIG news for the 123notary.com gang! There is new stuff to consider about timing:
The final Closing Disclosure must be delivered and received no later than 3 business days prior to closing.

If the lender sends the final documents 6 business days prior to closing, they don’t need to prove the buyer(s) receipt.

Most lenders will mail the closing disclosure 6 business days before closing. This pushes back the time frames for closing and makes it harder, if not impossible to address late breaking changes or issues in the days leading up to closing.
Fewer last minute notary requests: Lenders will have less time to get loans approved and the parties will have much more difficulty making last minute changes and adjustments.

You might also like:

The Closing Disclosure

The 4506, Name Affidavit, Deeds, and more documents explained

TRID information courtesy of Carmen

Index of information about documents



  1. The 6 days in advance requirement is already being universally ignored.

    Comment by JEROME ZEIGER — June 24, 2016 @ 1:17 am

  2. Still have BO’s receiving the CD the day before or the day of the signing!

    Comment by Sandra W LaRose — June 24, 2016 @ 1:09 pm

  3. Jerome, you are absolutely correct. At least 25% of the closings I do, the borrowers are not getting the CD prior to closing.

    Comment by Carol Logan — June 24, 2016 @ 1:54 pm

  4. I agree. I usually ask up front if the Borrower has received and reviewed the CD so I can get a feel for where they’re at in knowing their numbers and how prepared they are. Either they say they haven’t seen it or they received it but haven’t bothered to review it.

    Comment by Marie — June 24, 2016 @ 7:54 pm

  5. Why am I still not getting loan documents until two hours before the closing so I am printing and driving in a panic?

    Comment by Elise Dee Beraru — June 29, 2016 @ 11:31 pm

  6. Not only are the time frames being ignored, but I’ve had two refi loans now that I’m told to ignore the CD amount due and go by the Alta Settlement Statement.

    Comment by Doris Metzger — July 17, 2016 @ 2:46 am

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