AGENTS

The Closing Disclosure (CD) & TRID Guidelines

• Preparation and Delivery: The Closing Disclosure (CD) is used for most residential loan applications. The lender—not the closing agent—typically prepares and delivers the CD to the buyer/consumer at least three business days prior to the scheduled closing date.

• Information Deadlines: The closing agent must submit all relevant transaction details to the lender approximately 10 to 14 days prior to closing so the lender can finalize the CD on time.

• Buyer-Paid Charges: All buyer-paid charges must be communicated to the closing agent 10 to 14 days prior to closing.

• Agent Licensing Details: The closing agent requires your real estate brokerage’s state license number and your individual real estate license number for inclusion on the CD.

• Seller-Side Documentation: The CD sent to the buyer will not include the seller’s side of the transaction. The closing agent (not the lender) is responsible for providing the seller’s closing figures and may prepare a separate CD or settlement statement specifically for the seller.

• Access to the CD: You will likely not receive an advance copy of the CD before it reaches the buyer. While the lender typically sends a copy to the closing agent alongside the buyer delivery, the closing agent is restricted by privacy rules from sharing it with real estate agents without express written approval from the lender. You must obtain a copy directly from the borrower.

• Changes & Re-Disclosure Delays: Changes to the CD after delivery may trigger a mandatory new three-day waiting period if the change causes the Annual Percentage Rate (APR) to become inaccurate, the loan product changes, or a prepayment penalty is added.

• Appraisal & Valuation Adjustments: Changes affecting the property’s appraised value may trigger additional review periods under the Equal Credit Opportunity Act (ECOA).

• Pre-Settlement Inspections: Consider scheduling two walkthroughs: an initial walkthrough 7 to 10 days before closing, and a final verification walkthrough on the day of closing.

• Owner’s Title Insurance: The CD categorizes Owner’s Title Insurance as “optional.” Ask a Stewart Title representative for more information on the critical protections provided by an Owner’s Policy, or review Stewart Title’s educational resources at stewart.com.

• Contract Timelines: TRID requirements impact contract negotiations. A standard 30-day closing window may not provide adequate cushion. If the contract specifies a set number of days, adding a minimum buffer of 15 days is advisable. Ensure clear communication channels exist between all parties to immediately relay any contract amendments or lender requests.

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