Is Borrower Required to Sign Updated Version of Closing Disclosure?

The short answer is that it depends on the lender. So, settlement agents should read their closing instructions carefully. Generally, when a disclosure becomes inaccurate within three days before consummation and a new three day period is not required, TRID requires the lender to correct the disclosure and ensure the consumers receives the disclosure at or before closing. 12 CFR 1026.19(f)(2)(i).

Each lender will have different requirements for how they will want to correct disclosures, the timing for sending them to consumers and the documentation they will require for compliance purposes.

It is a safe bet that if the lender requires some documentation of receipt for the original Closing Disclosure, they will likely require the same protocol for corrected disclosures.

Comments

[J. Leary]

How is a title agent expected to get everyone on the same page for "consummation" when lenders are all doing their own thing? Even if the lender prepares the Closing Disclosure, the title agent will still have to enter the same information into their computer system in order to print the sellers side and disburse the file. This whole process is just ridiculous!! Worse than herding cats!! Does anyone realize the chaos this is causing our industry??!!

[Christine Schulte]

If the loan application was signed on 10/2/15, the lender does not need to comply with the closing disclosures? If the loan application was taken on 10/3/15 from that point forward everyone needs to follow to new rules, right???