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TRID – Closing Black Holes

Q: Currently, the Know Before You Owe/TILA-RESPA Integrated Disclosure Rule ("TRID") does not permit changes to a Closing Disclosure ("CD") to cure a tolerance violation more than four (4) business days prior to consummation. Is it true that, if enacted, the proposed TRID amendments will eliminate this issue known as the "Black Hole"?

A: Yes, in most instances the proposed amended language to TRID would permit a lender to reset tolerances using a CD at any time so long as the lender issues a corrected CD within three (3) business days of learning of a valid Change of Circumstances.

This will provide some reprieve for lenders who have been forced to absorb increased costs when closings were delayed.


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