The Closing Disclosure is the final disclosure document in the mortgage process under TRID. It must be received by the borrower at least 3 business days before closing, giving them time to review the final terms before signing.
What’s on the Closing Disclosure
The CD is a 5-page document covering: loan terms (page 1), projected payments (page 1), costs at closing (page 1), origination charges (page 2), services borrower did and did not shop for (page 2), other costs (page 2), summaries of transactions (page 3), loan disclosures (page 4), loan calculations (page 5), other disclosures (page 5), contact information (page 5), confirm receipt signature (page 5).
The 3-day rule and material changes
The 3-day waiting period between CD delivery and closing is a hard requirement. If material changes occur after the CD is delivered (rate change, APR increase exceeding 1/8%, prepayment penalty added, loan product change), a new CD must be issued and a new 3-day waiting period begins before closing can occur.
Three things that trigger a redisclosure of the CD
- APR change of more than 1/8% (1/4% for irregular loans like ARMs)
- Loan product change (e.g., from fixed to ARM)
- Prepayment penalty added that wasn’t previously disclosed
Other changes (closing cost adjustments, settlement date changes, last-minute fee changes within tolerance) generally don’t trigger a new 3-day wait, though they do require an updated CD.
