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Federal lending laws for the Illinois broker exam

TILA, RESPA, ECOA or TRID: which rule fits?

Use TILA for consumer-credit costs and terms, RESPA for covered settlement referrals and servicing, ECOA for credit discrimination and application rights, and TRID for the Loan Estimate and Closing Disclosure. Identify the problem first. Then check the loan's coverage, the required action and the correct clock.

Last reviewed:

What is the difference between the four?

Match the conduct to the law before counting days
Law or frameworkRegulationMain exam clues
TILA: Truth in Lending ActZAPR, finance charge, consumer-credit advertising, qualifying rescission rights
RESPA: Real Estate Settlement Procedures ActXCovered settlement-service kickbacks, unearned fee splits, mortgage escrow and servicing
ECOA: Equal Credit Opportunity ActBProhibited credit discrimination, action notices, qualifying appraisal and valuation copies
TRID: TILA-RESPA Integrated DisclosurePrincipally Z, under TILA and RESPA authorityLoan Estimate, Closing Disclosure and their delivery or receipt requirements

For example, an APR question concerns the cost of credit, even when the number appears on a TRID form. APR reflects interest and specified other borrowing costs; it is not simply another name for the note rate.

The same transaction can trigger several laws. A lender can owe a Loan Estimate under TRID and an action notice under ECOA. Choosing the main rule for one exam question does not erase the others.

The PSI booklet dated June 24, 2026, national IV.C.1 to IV.C.5 lists RESPA, TILA, TRID, ECOA and the lending process. They sit within Financing's 10% of the national broker portion. That allocation covers the whole financing area, not this page alone.

Which mortgage disclosure clock are you counting?

For a covered TRID transaction, keep delivery or mailing separate from consumer receipt. The rules and official commentary in 1026.19(e) and (f) make that distinction explicit.

Ordinary TRID timing, without a special exception or valid emergency waiver
RequirementWhat must happenBusiness-day definition
Initial Loan Estimate after applicationDeliver or mail no later than the third business day after the applicationCreditor offices open for substantially all business functions
Loan Estimate before consummationDeliver or mail no later than the seventh business day before consummationEvery calendar day except Sunday and specified federal legal public holidays
Closing Disclosure before consummationConsumer receives it at least three business days before consummationEvery calendar day except Sunday and specified federal legal public holidays

The seven-day Loan Estimate wait begins at delivery or mailing, not consumer receipt. The Closing Disclosure's three-day period is based on receipt. Where receipt matters under these provisions, a mailed disclosure is generally presumed received three business days after mailing unless the creditor has evidence of earlier receipt. Do not add that receipt period to the Loan Estimate's seven-day starting point.

Regulation Z, 1026.2(a)(3), (6) and (13) defines the application, business days and consummation. Consummation is when the consumer becomes contractually obligated on the credit transaction under applicable law. Do not automatically substitute funding, recording or the date of the home purchase contract.

The six application items are the consumer's name, income, Social Security number to obtain a credit report, property address, estimated property value and mortgage amount sought. Tax returns may be needed for underwriting, but they are not a seventh item that postpones this disclosure trigger. A TRID application is not necessarily a completed credit application under ECOA. Do not start every federal clock merely because the six TRID items have arrived.

Coverage matters. These integrated forms generally concern closed-end consumer credit secured by real property or a cooperative unit, excluding reverse mortgages covered by the separate rule. Do not automatically apply them to a HELOC or a loan secured only by a movable home. Specific exemptions also exist.

Worked example: which waiting period ends last?

An October 2026 purchase-loan timeline

Assume an ordinary covered loan, no waiver or disclosure correction, and creditor offices open Monday through Friday for substantially all business functions. The creditor receives all six items and mails the Loan Estimate on Monday, October 19, 2026. The consumer receives the Closing Disclosure in person on Thursday, October 22. There is no federal legal public holiday in the interval used below.

  • Loan Estimate application deadline: Tuesday 20, Wednesday 21 and Thursday 22 are days one through three. Mailing on Monday was earlier than the deadline.
  • Seven-day minimum after Loan Estimate mailing: count October 20, 21, 22, 23, 24, 26 and 27. Sunday 25 does not count. The seventh business day is Tuesday, October 27.
  • Three days after Closing Disclosure receipt: count Friday 23, Saturday 24 and Monday 26. That period permits consummation on Monday, October 26.

Tuesday, October 27 is the earliest date allowed by both of these ordinary waiting periods. The later Loan Estimate date controls. This example does not certify that every other loan requirement is satisfied.

Change the fact: if the Closing Disclosure is actually received in person on Friday, October 23, its three business days are Saturday 24, Monday 26 and Tuesday 27. Both periods then permit October 27. If receipt is not established in person, determine the applicable receipt rule before counting.

When does a referral become a RESPA problem?

A title company promises a broker a gift card for each buyer sent to it in transactions involving federally related mortgage loans. The broker performs no separate service for the payment. That is a thing of value tied to covered settlement-service referrals, the problem addressed by RESPA Section 8 and 1024.14. Calling it a marketing reward does not change those facts.

Do not replace this rule with “all referral fees are illegal.” Section 1024.14(g) includes an exception for cooperative brokerage and referral arrangements between real estate agents and brokers acting in a real estate brokerage capacity. It does not extend that exception to fee arrangements between real estate brokers and mortgage brokers. Payment for real services has its own conditions; a sham service does not cure a kickback.

Common ownership also needs a separate analysis. Section 1024.15 sets affiliated-business conditions involving written relationship and charge disclosures, restrictions on required use with specified exceptions, and permitted returns. A disclosure alone does not make every payment or arrangement lawful.

What does ECOA add beyond the mortgage forms?

Regulation B's prohibited-basis definition includes race, color, religion, national origin, sex, marital status, age when the applicant can enter a binding contract, receipt of public-assistance income and good-faith exercise of specified consumer-credit rights. Use ECOA's own list and exceptions, rather than copying a fair-housing mnemonic into every credit question.

For a completed consumer-credit application, Regulation B, 1002.9 generally requires notice of approval, counteroffer or adverse action within 30 days. Adverse-action notice must include specific reasons or the prescribed right to obtain them, along with the other required notice content. An incomplete application and a business-credit application have separate provisions. A Loan Estimate is not a credit-approval promise.

Section 1002.14 separately covers copies of appraisals and other written valuations developed for an application secured by a first lien on a dwelling. Copies generally must be provided promptly on completion or three business days before consummation or account opening, whichever is earlier. A permitted timing waiver does not waive the right to the copy.

Use the 2026 Regulation B amendment for changed topics

The CFPB overview identifies the July 21, 2026 amendments and says an updated regulation version will be published. The April 22 final rule, effective July 21, addresses disparate impact, discouragement and special purpose credit programs. Do not treat an older section or commentary display as proof that the pre-amendment effects-test wording still controls.

The CFPB describes removal of the regulatory effects test, a narrower discouragement provision and revised special purpose program rules. The amendment does not authorize intentional discrimination on ECOA's prohibited bases. This comparison does not decide a court dispute, a special purpose program or the legality of an individual credit decision.

Try two original lending-law questions

These are original study items, not released or recalled PSI questions.

1. A seller credit changes before consummation

A covered loan already has a timely Closing Disclosure. The seller credit increases. The APR remains accurate under Regulation Z, the loan product stays the same and no prepayment penalty is added. Which response best fits the disclosure rule?

  1. Restart the three-day wait for every changed dollar amount
  2. Use ECOA to approve the loan automatically
  3. Provide a corrected disclosure at or before consummation without a new three-day wait solely for this change
  4. Ignore the change because the first disclosure was timely

C is correct. A invents a universal restart. B confuses a disclosure with credit approval. C follows the correction rule on these facts. D ignores the need for an accurate corrected disclosure.

Change the fact: the product changes from fixed rate to an adjustable-rate product. A new three-business-day receipt period applies to the corrected Closing Disclosure.

2. The creditor acts on a completed application

An exam question asks which law generally requires notice within 30 days after a completed consumer-credit application, including a denial notice with reasons or the required right-to-reasons disclosure. Which is the best answer?

  1. ECOA and Regulation B
  2. RESPA Section 8
  3. TILA's purchase-mortgage rescission rule
  4. TRID's Closing Disclosure waiting period

A is correct. A concerns the credit action and notice. B concerns covered settlement referrals and fees. C mistakes an exempt purchase transaction for a universal cancellation right. D concerns pre-consummation disclosure review, not the 30-day action notice.

Change the fact: the question asks which framework requires the Closing Disclosure three business days before consummation. D now identifies that disclosure framework. ECOA duties can still coexist.

Common lending-law questions

The purchase-transaction exemption and other rescission conditions are in 1026.23. A qualifying nonpurchase loan secured by the principal dwelling raises a different question from a standard purchase loan.

Is TRID a fourth standalone lending law?

No. TRID means TILA-RESPA Integrated Disclosure. It combines specified mortgage disclosures under those laws, principally through Regulation Z. It does not replace RESPA's referral rules or ECOA's credit-decision duties.

Do all mortgage changes restart the three-day Closing Disclosure wait?

No. Under 1026.19(f)(2)(ii), a new wait applies when the disclosed APR becomes inaccurate under the applicable rules, the loan product changes or a prepayment penalty is added. Other changes can require corrected disclosures at or before consummation without a new three-business-day wait. A changed APR number is not automatically an inaccurate APR under the regulation.

Do I have three days to cancel after buying a home?

The Closing Disclosure review period is not a universal right to cancel a home purchase after closing. TILA rescission has different coverage, timing and exceptions. A standard loan secured by the new principal dwelling to finance its purchase is a residential mortgage transaction exempt from that rescission right.

Practice the issue before memorizing a deadline

Use the full lending-process guide when you need the wider sequence, or try the free broker questions. If short phone sessions help you study, you can download Pass Illinois for additional practice. Explain which law applies and which fact would change the answer.