Illinois real estate exam glossary
TRID: forms, timing and fee tolerances
A lender sends a disclosure on Monday. That does not always mean the consumer received it on Monday, and the word “business day” does not always mean Monday through Friday. TRID questions become easier when you identify the form, the triggering event and the correct calendar before counting.
Last reviewed:
The short answer
TRID means TILA-RESPA Integrated Disclosure. For covered closed-end consumer loans secured by real property or a cooperative unit, the main forms are the Loan Estimate and Closing Disclosure. The Loan Estimate is generally delivered or mailed within three creditor-business days after the six-piece application and at least seven specific business days before consummation. The Closing Disclosure generally must be received at least three specific business days before consummation. Fees, revisions, receipt and exceptions have separate rules.
Reviewed October 27, 2026. National IV.C.3 of the PSI Illinois broker outline covers TRID requirements and time frames. The whole Financing domain has ten of 100 scored national questions across several subjects, not ten on TRID alone. These are original teaching questions, not recalled PSI items or a validated readiness score. The examples concern ordinary covered transactions with stated calendars and no unstated exception or waiver.
Identify the form, trigger, calendar and charge category
- Test coverage before counting. The ordinary rule concerns closed-end consumer credit secured by real property or a cooperative unit, other than the specified reverse mortgages. A covered construction, refinance, vacant-land or subordinate-lien transaction is not excluded merely because it is not a home purchase. HELOCs, reverse mortgages and a dwelling secured only as personal property use different disclosure rules. Creditor status, purpose and any actual exemption still matter; “small lender” is not a blanket exemption. Section 1026.3(h) offers specified partial treatment for qualifying assistance transactions under multiple conditions and a disclosure choice. It does not exempt every assistance loan or remove every other applicable Regulation Z duty.
- Identify the six-piece application. The defined information is the consumer’s name, income, Social Security number to obtain a credit report, property address, estimated property value and mortgage amount sought. The rule addresses a permitted alternative identifier when a consumer lacks a Social Security number. The creditor can seek more information but cannot demand verifying documents as a condition of providing the Loan Estimate or add a seventh item to delay the clock. A prequalification label does not override the actual submission.
- Use two different business-day tests. For the ordinary initial three-day Loan Estimate deadline, count days when the creditor is open to the public for substantially all business functions. Limited teller service alone is not necessarily enough. For the seven-day wait, deemed receipt, the revised-Loan-Estimate receipt cutoff and the Closing Disclosure waiting period, use all calendar days except Sundays and the legal public holidays specified by the rule. Saturday ordinarily counts for that specific test even when the lender is closed.
- Keep delivery and receipt separate. The initial Loan Estimate generally must be delivered or mailed within three general business days after application. Its seven-specific-business-day waiting period begins with delivery or mailing, not presumed receipt. Non-personal delivery has a three-specific-business-day receipt presumption, with permitted evidence of earlier actual receipt. Electronic disclosure also needs the applicable E-Sign consent and other requirements; an email timestamp alone does not prove every condition.
- Apply the early-fee restriction to more than payment collection. Generally no creditor or other person may impose an application-related fee before the consumer receives the Loan Estimate and indicates intent to proceed. A bona fide and reasonable credit-report fee is the limited ordinary exception. Requiring a check or card authorization for a later appraisal or processing charge can impose the fee even if it will not be cashed or charged yet. Silence is not documented intent to proceed, and intent is not underwriting approval or an automatic rate lock.
- Identify shopping permission and who receives the charge. A required shoppable service needs the stated written list, including an available provider and notice that the consumer may choose another. Requiring the consumer to pick only from the list is not genuine shopping permission under the rule. Passing a charge through the creditor to someone else does not, by itself, make it a fee paid to the creditor. The actual service, recipient, affiliate relationship, list and consumer choice determine the good-faith category.
- Apply the zero-tolerance general rule with its exceptions. Creditor, mortgage-broker, affiliate and required nonshoppable service charges, and transfer taxes, generally fall under the no-increase rule unless a lawful revised baseline applies. But bona fide charges in the rule’s permitted-variation categories retain that treatment even when paid to the creditor or an affiliate. Do not classify prepaid interest or an insurance premium solely from the recipient’s name. “Zero tolerance” describes the comparison rule, not a promise that no corrected charge can ever change.
- Test the 10% category as an aggregate. Recording fees and qualifying required services from unaffiliated providers where shopping is permitted and the consumer uses a listed provider or does not select one are generally grouped for this test. A shoppable affiliate service does not enter this category merely because shopping was allowed. Use unrounded comparison amounts and charges for services actually performed; remove a service never obtained from the estimated aggregate. A large increase in one item does not alone prove the group exceeds its permitted total.
- Retain good faith for permitted variations. Prepaid interest, property insurance, escrow deposits, property taxes, qualifying off-list shoppable services and non-required services generally permit variation under their actual conditions. The original estimate must still use the best information reasonably available, and the stated bona fide requirement matters. A deliberately understated known charge is not excused by the absence of a percentage cap. Missing a required shopping list can change the analysis; it does not automatically make an off-list selection unlimited.
- Separate an informational update from a valid new tolerance baseline. Permitted reasons include defined changed circumstances, affected eligibility, consumer-requested changes, the stated rate-lock rule, qualifying expiration and delayed new-construction circumstances. Only increases caused by the allowed reason can use that new basis, with the required documentation and timing. Under the specified changed-circumstance rule, a 10% group increase must cross the relevant aggregate threshold to reset that comparison. A provider’s higher price or a revised PDF alone does not establish a reset. The ordinary revision deadline is three general business days after receiving sufficient information to establish the permitted reason. Expiration can depend on more than ten general business days or a longer period the creditor actually communicated; do not automatically treat day eleven as a reset in every file.
- Respect the last Loan Estimate cutoff and the creditor’s final-disclosure responsibility. A revised Loan Estimate cannot be provided on or after the date the Closing Disclosure is provided, and its ordinary receipt cutoff is four specific business days before consummation. Appropriate revised estimates may instead appear in the Closing Disclosure under the actual rules. The creditor generally must ensure Closing Disclosure receipt three specific business days before consummation even if a settlement agent assists. Consummation is the credit obligation under applicable law, not automatically the sale-contract, funding or recording date.
- Correct changed final terms without inventing a new wait. A new Closing Disclosure waiting period follows an APR that is inaccurate as defined by Section 1026.22, a product change that makes the product disclosure inaccurate, or addition of a prepayment penalty that makes its disclosure inaccurate. Not every APR movement or cash-to-close change is such a trigger. Other pre-consummation changes generally need corrected disclosures received at or before consummation. The specified tolerance refund and corrected-disclosure process has a sixty-calendar-day limit after consummation; it is not the deadline for every kind of correction or every legal remedy.
| Event | Deadline | Business-day rule |
|---|---|---|
| Initial Loan Estimate | Deliver or mail within 3 business days after application | General creditor-open test; check actual exceptions |
| Initial seven-day wait | Deliver or mail at least 7 business days before consummation | Specific calendar; starts on delivery or mailing |
| Non-personal receipt | Ordinarily deemed received after 3 business days | Specific calendar; evidence of earlier receipt can matter |
| Revised Loan Estimate | Ordinary receipt at least 4 business days before consummation | Specific calendar; no revised LE on or after CD date |
| Closing Disclosure | Ordinary receipt at least 3 business days before consummation | Specific calendar; actual or proper deemed receipt |
| Specified tolerance cure | Refund and corrected disclosure within 60 calendar days after consummation | Calendar days; not the rule for every correction |
The distinctions that matter
| Distinction | How it works | What to notice |
|---|---|---|
| TRID vs. TILA | TILA is the statute. TRID is the integrated mortgage-disclosure framework implemented mainly through Regulation Z. | Broad credit law versus disclosure system. |
| Loan Estimate vs. Closing Disclosure | The Loan Estimate supports early shopping with estimated terms. The Closing Disclosure supports final review of actual transaction terms. | Estimate early versus final before consummation. |
| Application vs. prequalification | A TRID application exists when the six defined pieces are submitted. Prequalification is an informal label that does not override receipt of those items. | Federal data trigger versus marketing stage. |
| Intent to proceed vs. loan approval | Intent communicates the consumer’s choice to continue. The ordinary fee restriction requires both estimate receipt and intent. Neither event is underwriting approval, an automatic rate lock or permission to charge a fee prohibited elsewhere. | Keep processing versus accept credit risk. |
| General vs. specific business day | The general test is a day the creditor is open to the public for substantially all business functions. The specific test excludes Sundays and the legal public holidays specified by the regulation; an observed office closure is not automatically an excluded day. | Office schedule versus federal calendar. |
| Delivery vs. receipt | Initial delivery or mailing can start one clock; actual or deemed receipt starts another. Non-personal and electronic receipt have stated presumptions, evidence and consent requirements. | Sent versus received. |
| Zero tolerance vs. 10% aggregate | The general no-increase rule and actual exceptions differ from the 10% aggregate category. Provider affiliation, service type, shopping and the permitted-variation rules matter. | No increase versus group ceiling. |
| Permitted variation vs. no good-faith duty | A category without a numerical increase cap still requires best reasonably available information and the actual bona fide conditions. It is not permission to understate known costs. | Flexible result versus careless estimate. |
| Changed circumstance vs. market increase | A changed circumstance must fit the regulatory event or information test. A provider simply raising price does not automatically qualify. | Defined cause versus ordinary cost growth. |
| Revised Loan Estimate vs. corrected Closing Disclosure | A valid revision can change the comparison basis only under its actual grounds and timing. No revised Loan Estimate may be provided on or after the Closing Disclosure date; later changes use the appropriate final-disclosure process. | Revised estimate versus corrected final. |
| Consummation vs. recording | Consummation occurs when the consumer becomes contractually obligated on credit under state law. Recording gives public notice of an instrument. | Credit obligation versus land-record filing. |
| Three-day CD review vs. rescission | The Closing Disclosure review period precedes consummation. Any applicable rescission right has its own coverage, events, notice and exceptions; the two clocks are separate. | Review first versus cancel qualifying credit later. |
Work through the facts
Six pieces start the clock
On Monday, a creditor receives a borrower's name, monthly income, Social Security number for credit, property address, value estimate, and requested loan amount. Assume an ordinary covered transaction, no denial, withdrawal, timeshare or other exception, no holidays, and offices open for substantially all functions Monday through Friday.
- All six application elements have arrived.
- The creditor cannot wait for tax returns or the purchase contract to recognize the application.
- If its offices perform substantially all functions Monday through Friday, Thursday is the third general business day.
Answer: Deliver or mail the Loan Estimate by Thursday under the stated application clock. The separate seven-day wait and Closing Disclosure timing also must be met; this does not approve consummation on Thursday.
Fee restriction
Before delivering a Loan Estimate, a lender asks the consumer to pay a $600 appraisal fee and a $35 credit-report fee. The consumer has neither received the estimate nor indicated intent. Assume the $35 is a bona fide and reasonable charge for obtaining the consumer’s credit report in a covered transaction.
- The consumer has not received the Loan Estimate or indicated intent to proceed.
- A bona fide reasonable credit-report fee can fit the limited exception.
- The appraisal fee cannot generally be imposed yet.
Answer: The supplied credit-report fee fits the limited exception; the appraisal fee cannot yet be imposed. Calling the $600 a deposit or taking payment authorization now does not automatically avoid the restriction.
Calculate the CD waiting period
The consumer receives the Closing Disclosure in person on Thursday. No federal holiday occurs, and consummation is planned for Monday. Assume the initial Loan Estimate wait and all other timing requirements are already satisfied, with no restart event or other exception.
- Friday is business day one.
- Saturday is business day two.
- Sunday is excluded, and Monday is business day three.
Answer: Monday is the third specific business day after Thursday receipt on these supplied facts. This is not a universal seventy-two-hour clock or a determination that every other closing condition is satisfied.
Loan product change restarts waiting
After the initial Closing Disclosure, the creditor changes the loan from a fixed-rate mortgage to an adjustable-rate mortgage. Assume the change makes the required product disclosure inaccurate in an otherwise covered ordinary transaction and no waiver is supplied.
- Fixed to adjustable is a loan-product change.
- A corrected Closing Disclosure is required.
- The consumer must receive it and complete a new three-specific-business-day waiting period.
Answer: The product change restarts the three-day wait.
Tax proration does not restart waiting
A final walk-through and updated county figure change the seller-buyer tax proration after the Closing Disclosure. The exercise stipulates that the APR remains accurate under Section 1026.22, the product is unchanged and no prepayment penalty is added.
- The proration must be corrected on the final disclosure.
- It is not an inaccurate APR, product change, or added prepayment penalty.
- The creditor can provide a corrected Closing Disclosure at or before consummation under the applicable rule.
Answer: Provide the appropriate corrected disclosure received at or before consummation. The stated proration alone does not require a new three-day waiting period; do not ignore an actual separate restart trigger.
Ten-percent aggregate test
A covered exercise supplies $2,000 of estimated charges and $2,230 actually paid, all properly in the 10% aggregate category. Required shoppable services use unaffiliated listed providers, the list and permission comply, all estimated services were performed, the numbers are unrounded, and no valid revised baseline or other adjustment applies.
- Ten percent of $2,000 is $200.
- The permitted aggregate is therefore $2,200.
- Actual charges exceed that amount by $30.
Answer: The comparison excess is $30, not the full $230 increase and not 10% of the loan amount. The specified cure requires the actual refund and corrected disclosure within sixty calendar days after consummation; this does not resolve every other legal issue.
No numerical tolerance still requires good faith
A creditor intentionally understates prepaid interest even though the rate and expected consummation date are known.
- Prepaid interest generally has no numerical tolerance.
- The estimate still must use the best information reasonably available and be made in good faith.
- The absence of a percentage cap does not authorize deliberate understatement.
Answer: No numerical cap does not excuse a knowingly poor estimate. Apply the actual good-faith rule rather than assuming every permitted variation is unlimited or every later increase is itself unlawful.
Both waiting periods must be satisfied
In an ordinary covered transaction, the initial Loan Estimate is hand-delivered on Monday of week 1. The Closing Disclosure is received in person on Friday of week 1. Assume no holidays, no waiver, no changes requiring another wait and no other timing issue.
- For the seven-day wait, count Tuesday, Wednesday, Thursday, Friday, Saturday, Monday and Tuesday.
- For the three-day Closing Disclosure wait, count Saturday, Monday and Tuesday after Friday receipt.
- Sunday is excluded from both specific-day counts.
Answer: Both supplied waiting periods permit consummation no earlier than Tuesday of week 2. The completed Closing Disclosure period does not waive the separate initial Loan Estimate wait.
Remove the service that was never performed
An ordinary covered exercise has a $2,000 initial 10% aggregate estimate, including a $200 service that was never performed. All remaining estimated services were performed. Their actual eligible charges total $2,050. All category, unaffiliated-provider, shopping-list and selection requirements are met. Use unrounded amounts, with no valid revised baseline, replacement service or other adjustment.
- Remove the unused $200 estimate: $2,000 − $200 = $1,800.
- The eligible group ceiling is $1,800 × 1.10 = $1,980.
- $2,050 − $1,980 = $70 exceeds that comparison ceiling.
Answer: The specified comparison excess is $70. Leaving the unused estimate in the base would create improper headroom. Apply the required refund and corrected-disclosure process; this is not an audit of every charge or legal remedy.
Keep two tolerance calculations separate
In an otherwise covered exercise, a no-increase fee was estimated at $900 and paid at $940. A separate, properly classified 10% aggregate was estimated at $2,000 and paid at $2,230. All group services were performed, all shopping, list, recipient and affiliation conditions are met, the amounts are unrounded, and no valid revised baseline or other adjustment applies.
- The no-increase charge exceeds its comparison amount by $940 − $900 = $40.
- The 10% group ceiling is $2,000 × 1.10 = $2,200, giving a separate $30 excess.
- The supplied excesses total $40 + $30 = $70.
Answer: Refund the supplied $70 excess and deliver or mail the corrected disclosure reflecting that refund within sixty calendar days after consummation under the specified cure rule. This does not establish that every other violation, private claim or disclosure issue is cured.
Mistakes to avoid
- Calling TRID a separate statute It is an integrated disclosure framework implemented mainly through Regulation Z.
- Using TRID forms for a HELOC HELOCs use separate open-end Regulation Z disclosures.
- Demanding a purchase contract before recognizing an application Receipt of the six defined pieces starts the Loan Estimate clock.
- Using only weekdays for every deadline The specific calendar generally counts Saturday, excludes Sunday and excludes the specified actual legal public holidays. Do not automatically substitute an observed office-closure date.
- Charging an appraisal fee before Loan Estimate and intent Only a bona fide reasonable credit-report fee fits the ordinary early-fee exception.
- Calling intent to proceed loan approval Estimate receipt and intent are separate prerequisites to imposing ordinary application-related fees. Intent alone is not approval or permission for a charge prohibited under another rule.
- Calling a Loan Estimate a rate lock The form states whether the rate is locked and the lock's timing; delivery alone does not lock it.
- Applying 10% to each fee separately That tolerance is tested across the applicable category in aggregate.
- Treating no tolerance as permission to guess All estimates remain subject to the good-faith and best-information standards.
- Revising estimates whenever a provider raises price The revision needs a regulatory reason that actually caused the increased charge.
- Sending a revised LE after the Closing Disclosure No revised Loan Estimate may be provided on or after the date the Closing Disclosure is provided, including earlier on that same date. Apply the appropriate final-disclosure process instead.
- Restarting the CD wait for every change Only an APR inaccurate as defined by Section 1026.22, the specified product change or an added prepayment penalty triggers the new wait. A mere APR change is not enough.
- Calling the CD wait a right to rescind It is a pre-consummation review period, not a post-closing cancellation right.
- Using recording as consummation Consummation depends on when the consumer becomes contractually obligated under applicable state law.
- Treating a pending rulemaking request as current law The July 9, 2026 RFI requested information; it did not itself amend the rule. Use the operative regulation rather than treating a proposal or request as an effective change.
- Treating every affiliate payment as the same fee category Recipient affiliation, service type and the permitted-variation exception must be read together. A required shoppable affiliate service is not a 10% item merely because shopping is permitted.
- Keeping an unperformed service in the aggregate estimate The comparison base includes services actually performed. An unused estimate cannot create extra 10% headroom.
Check your understanding
These are original teaching questions, not recalled or predicted PSI questions. Answer first, then explain why the other choices fail.
1. What does TRID integrate?
- The deed and appraisal
- Zoning and building codes
- TILA and RESPA mortgage disclosures
- ECOA and CERCLA
Show answer and explanation
Answer: C. TILA and RESPA mortgage disclosures
The two principal forms are the Loan Estimate and Closing Disclosure.
2. How many defined data pieces create a TRID application?
- Four
- Six
- Five
- Ten
Show answer and explanation
Answer: B. Six
The creditor cannot add a seventh piece to delay the federal clock.
3. When is the Loan Estimate generally due?
- Thirty days after appraisal
- Within three general business days after application
- After final approval only
- At consummation only
Show answer and explanation
Answer: B. Within three general business days after application
It also must be delivered or mailed at least seven specific business days before consummation.
4. Which fee can generally be imposed before LE receipt and intent to proceed?
- The appraisal fee
- A bona fide reasonable credit-report fee
- The full origination charge
- The underwriting fee
Show answer and explanation
Answer: B. A bona fide reasonable credit-report fee
Other fees ordinarily wait until both required events occur.
5. Which day ordinarily counts under the specific Closing Disclosure business-day definition, unless that day is a specified legal public holiday?
- Saturday
- Every federal holiday
- No calendar day
- Sunday
Show answer and explanation
Answer: A. Saturday
The specific definition excludes Sundays and federal legal public holidays.
6. Which change requires a new Closing Disclosure waiting period in a covered transaction, assuming it makes the required product disclosure inaccurate and no waiver applies?
- The loan product changes from fixed to adjustable
- A typo in the broker address is corrected
- A tax proration changes
- The seller credit decreases slightly
Show answer and explanation
Answer: A. The loan product changes from fixed to adjustable
The specified product change triggers corrected disclosures received three specific business days before consummation. An APR inaccurate as defined by Section 1026.22 and an added prepayment penalty are the other triggers; a mere APR change is not necessarily inaccurate.
7. How is the 10 percent tolerance tested?
- Against the appraisal value
- Across the applicable charges in aggregate
- Against each individual fee only
- Against the loan amount
Show answer and explanation
Answer: B. Across the applicable charges in aggregate
Individual items can move more or less as long as the applicable total stays within the permitted increase.
8. Can a revised Loan Estimate be provided on or after the date the Closing Disclosure is provided?
- Only after recording
- No
- Only by the real estate broker
- Yes, at any time
Show answer and explanation
Answer: B. No
The prohibition includes the same date, not only a later day. Use the appropriate Closing Disclosure correction process; a new tolerance basis still needs its own valid grounds and timing.
9. Does intent to proceed guarantee loan approval?
- Only in Illinois
- No
- Yes
- Only for FHA
Show answer and explanation
Answer: B. No
Underwriting and property approval remain separate.
10. What did the CFPB's July 9, 2026 mortgage RFI do?
- Repealed the Closing Disclosure
- Requested public information without itself changing TRID
- Changed the application to seven pieces
- Eliminated all waiting periods immediately
Show answer and explanation
Answer: B. Requested public information without itself changing TRID
The July 9 request solicited information; the request itself was not a final amendment. The actual operative regulation governs. This is not a claim that every later regulatory action has been audited or that the comment period remains open.
11. An estimate of $2,000 and actual charges of $2,230 all properly belong in the 10% aggregate group. All services were performed and no valid revision applies. What is the comparison excess?
- $30
- $230
- $200
- $2,230
Show answer and explanation
Answer: A. $30
The group ceiling is $2,000 × 1.10 = $2,200. Actual charges exceed it by $30. Classify the fees and comparison basis first; do not use 10% of each fee or of the loan amount.
12. A required title service is shoppable but is paid to a creditor affiliate. No permitted-variation exception or revised baseline applies. Does shopping alone place that fee in the 10% category?
- Yes; all title work is 10%
- Yes; the loan amount decides the category
- Yes; every shoppable fee is 10%
- No; the affiliate condition prevents that classification
Show answer and explanation
Answer: D. No; the affiliate condition prevents that classification
The 10% rule has an unaffiliated-service condition. Actual service and recipient facts matter; a list entry alone is not enough. Bona fide permitted-variation categories have their own treatment.
13. An email transmits the Closing Disclosure on Monday. No evidence of earlier receipt is supplied and there are no holidays. Under the ordinary presumption, when is it received?
- Only when recording occurs
- After exactly thirty calendar days
- Automatically Monday
- Thursday
Show answer and explanation
Answer: D. Thursday
Count three specific business days after transmission: Tuesday, Wednesday and Thursday. Proper electronic delivery and E-Sign requirements must be satisfied; no private notice method is approved here.
14. With actual Closing Disclosure receipt on Thursday and no holidays, which supplied days count toward the ordinary three-day wait?
- Thursday, Friday and Saturday
- Friday, Sunday and Monday
- Friday, Saturday and Monday
- Only three days when the lender is open
Show answer and explanation
Answer: C. Friday, Saturday and Monday
Count after receipt and exclude Sunday. The exercise assumes other waits and requirements are satisfied; this is a day-count rule, not an exact seventy-two-hour requirement.
15. A lender requires a $600 appraisal-payment authorization before Loan Estimate receipt and intent to proceed but promises to charge it later. What is the issue?
- There is no restriction until the card is charged
- The consumer’s silence is sufficient intent
- Requiring the payment method can impose the fee too early
- Appraisal fees are the credit-report exception
Show answer and explanation
Answer: C. Requiring the payment method can impose the fee too early
The restriction concerns imposing the fee, including a required payment method, not only taking the money. The bona fide reasonable credit-report exception does not cover an appraisal fee.
16. A corrected Closing Disclosure only removes a previously added prepayment penalty, with no other change or trigger. What does the identified commentary provide?
- The removal itself authorizes an unlawful original penalty
- Another wait is always required for removal
- No corrected form is ever needed
- Correction at or before consummation without another wait for removal alone
Show answer and explanation
Answer: D. Correction at or before consummation without another wait for removal alone
The added-penalty trigger is not the same as removal. Other changes and the original charge’s lawfulness remain separate; actual disclosure requirements still apply.
17. The seller-buyer tax proration changes, but the APR stays accurate, the product is unchanged and no penalty is added. What generally follows?
- A mandatory new wait for every dollar change
- Permission to leave the final form inaccurate
- A corrected Closing Disclosure without a new three-day wait for that change alone
- Automatic cancellation of the loan
Show answer and explanation
Answer: C. A corrected Closing Disclosure without a new three-day wait for that change alone
The rule distinguishes correction from a new waiting period. The question expressly supplies the absence of all three restart triggers and assumes applicable ordinary timing.
18. Can a higher updated fee on a revised form always replace the original tolerance baseline?
- Yes; if the provider wants a higher price
- Yes; any new PDF resets the limit
- No; valid grounds, actual causation, documentation and timing are required
- Yes; if the loan is close to consummation
Show answer and explanation
Answer: C. No; valid grounds, actual causation, documentation and timing are required
Informational updates and permitted comparison revisions are different. Only affected increases under an allowed reason can use the revised basis, subject to the actual rules.
19. Does a qualifying partial exemption under Section 1026.3(h) erase every Regulation Z duty?
- Yes; no disclosures can ever be provided
- Yes; every housing-assistance loan is unregulated
- Yes; all subordinate liens are exempt
- No; it concerns specified disclosures under actual conditions
Show answer and explanation
Answer: D. No; it concerns specified disclosures under actual conditions
The provision has multiple conditions and a specified disclosure choice. Other applicable requirements can remain; no live assistance program is classified by this question.
20. Does the Closing Disclosure review period itself create a post-consummation cancellation right?
- Yes; it automatically cancels every mortgage
- Yes; it replaces all state contract law
- Yes; it gives every purchase borrower three more days after closing
- No; any applicable rescission right has separate rules
Show answer and explanation
Answer: D. No; any applicable rescission right has separate rules
Pre-consummation disclosure review differs from rescission. Coverage, triggering events, notice and exceptions must be analyzed under the actual rescission rule.
21. A proper $2,000 aggregate estimate includes an unused $200 service. The remaining actual eligible charges total $2,050; no valid revision or other adjustment applies. What is the comparison excess?
- $0 because $2,050 is below $2,200
- $200
- $70
- $250
Show answer and explanation
Answer: C. $70
Remove the service never performed: $1,800 × 1.10 = $1,980. The actual $2,050 exceeds that ceiling by $70. The exercise supplies all other category, provider, shopping-list and unrounded-amount conditions.
22. A properly classified no-increase fee rises from $900 to $940 and a separate eligible $2,000 aggregate rises to $2,230. No valid revision applies. What do the supplied excesses total?
- $230
- $70
- $270
- $40
Show answer and explanation
Answer: B. $70
The separate no-increase excess is $40. The group ceiling is $2,200, making its excess $30. The total is $70, not every dollar of the combined increases. Actual refund and corrected disclosure are required under the specified sixty-calendar-day process.
23. Does any change in the disclosed APR automatically restart the Closing Disclosure waiting period?
- No APR inaccuracy can ever restart it
- Yes; even a change expressly treated as accurate restarts it
- Yes; every change of any size restarts it
- No; apply the accuracy provisions of Section 1026.22
Show answer and explanation
Answer: D. No; apply the accuracy provisions of Section 1026.22
The trigger is an APR inaccurate as defined by the rule. Regular and irregular transactions have different ordinary tolerances, with additional mortgage accuracy provisions. Do not substitute a universal numerical-difference shortcut.
24. Independence Day falls on Saturday, July 4, 2026, and the office observes it Friday, July 3. For the specific calendar, what do the stated holiday facts establish?
- Friday is not excluded merely as the observed closure; Saturday is the actual specified holiday
- Both days must always be excluded under the specific test
- Saturday always counts even on the actual specified holiday
- Friday’s closure automatically answers the general and specific tests alike
Show answer and explanation
Answer: A. Friday is not excluded merely as the observed closure; Saturday is the actual specified holiday
The specific definition turns on the actual specified legal holiday, not the office’s substitute closure. The general creditor-open test is different. This is not a complete holiday list, an approval of every receipt method or a private closing-date calculation.
Common questions
What does TRID stand for?
TILA-RESPA Integrated Disclosure. It brings the relevant Truth in Lending Act and Real Estate Settlement Procedures Act mortgage disclosures into the Loan Estimate and Closing Disclosure framework for covered transactions. It is not a third separate act of Congress. The operative requirements are mainly in Regulation Z, with related rules retaining their actual scope.
Which loans use the Loan Estimate and Closing Disclosure?
The ordinary rule concerns covered closed-end consumer credit secured by real property or a cooperative unit, other than the specified reverse mortgages. A refinance, construction loan, vacant-land loan or subordinate lien can qualify. HELOCs, reverse mortgages and a dwelling secured only as personal property have different disclosure rules. Purpose, creditor status and actual exceptions matter; neither “small lender” nor “housing assistance” is a blanket exemption from every requirement.
What six pieces make a TRID application?
Name, income, Social Security number for obtaining a credit report, property address, estimated property value and mortgage amount sought. The commentary permits an appropriate substitute credit-report identifier when the consumer lacks a Social Security number. A prequalification label or a request for more processing information does not undo receipt of those six items. Verifying documents cannot be demanded as a condition of giving the required Loan Estimate.
When is the Loan Estimate due?
Ordinarily, deliver or mail it no later than the third general business day after receiving the application and at least seven specific business days before consummation. The first clock depends on substantially all creditor business functions; the second excludes Sundays and the specified legal public holidays. The seven-day wait starts with delivery or mailing. Denial, withdrawal, timeshare and other actual exceptions must be checked rather than assumed.
Are Saturdays business days for TRID?
For the specific calendar used by the ordinary seven-day wait, deemed receipt and Closing Disclosure waiting period, Saturday ordinarily counts unless it is a specified legal public holiday. The general creditor-open test is different and depends on actual substantially-all-business activity. A bank holiday or limited teller opening is not automatically the answer for both definitions. Use the rule applicable to the particular deadline.
Can the lender charge an appraisal fee before providing the estimate?
Generally not before the consumer receives the Loan Estimate and indicates intent to proceed. A bona fide and reasonable credit-report fee is the limited ordinary exception. Requiring an appraisal check or card authorization now can impose the fee even if charging is postponed. Receipt, intent and the actual fee matter; a lender cannot treat silence as documented intent.
When must the consumer receive the Closing Disclosure?
Ordinarily at least three specific business days before consummation. Non-personal delivery has a three-business-day deemed-receipt rule; permitted evidence of earlier actual receipt can matter. Electronic delivery must satisfy the applicable consent and other E-Sign requirements. Mailing or emailing three days before the planned consummation is not automatically enough when the receipt presumption also must be counted.
Which changes require another three-day wait?
An APR inaccurate as defined by Section 1026.22; a product change that makes the required product disclosure inaccurate; or addition of a prepayment penalty that makes its disclosure inaccurate. Correct all changed terms under the applicable process. The word “inaccurate” matters: a changed APR is not automatically outside the rule’s accuracy provisions. Removing a penalty alone, without another trigger, is different from adding one.
What are the three fee-tolerance categories?
A general no-increase category, a limited 10% aggregate category and permitted-variation categories without a numerical increase cap. Required shopping, actual provider choice, the written list, affiliation, service type and the actual comparison baseline matter. A transfer tax is not the same as a recording fee. Bona fide prepaid interest, insurance, escrow and other specified categories must be read with their actual exceptions, not classified from the payee’s name alone.
How is the 10% aggregate test calculated?
Compare the eligible group’s unrounded actual charges with its proper estimated total multiplied by 1.10. A $2,000 group estimate has a $2,200 ceiling; a $2,230 actual total exceeds it by $30. Include only the correct category and services actually performed. A fee increasing more than 10% does not by itself mean the aggregate failed, and an unused service estimate cannot create extra headroom.
Can the lender reset fees whenever an estimate changes?
No. A new disclosure can inform the consumer without establishing a lawful new tolerance baseline. The permitted reason must actually cause the affected increase, and the required documentation and timing must be met. The changed-circumstance route for a 10% group has its own aggregate threshold. Consumer requests, rate locks, qualifying expiration and specified delayed-construction circumstances have separate conditions.
Can a revised Loan Estimate be provided with the Closing Disclosure?
Not on or after the date the Closing Disclosure is provided. A revised Loan Estimate also has an ordinary four-specific-business-day receipt cutoff before consummation. Under the actual rules, an appropriate revised estimate can appear in the Closing Disclosure instead. This does not make every later fee increase allowable or remove the need for a valid reason and timely disclosure.
Is intent to proceed a rate lock or loan approval?
No. It is the consumer’s communicated choice to continue with the transaction described by the estimate, documented as required. It is not underwriting approval, a commitment that every term is available or an automatic rate lock. The creditor may require a particular communication method; silence alone does not establish intent. Rate-lock and approval terms need their own review.
Did the July 2026 CFPB request change these rules?
The July 9, 2026 request sought information about possible changes to TRID, rescission and reverse-mortgage disclosures. The request itself was not a final amendment. This lesson uses the identified operative Regulation Z provisions reviewed in October 2026. It does not treat a regulation-wide version date as a new amendment to every section or assume that an old comment-submission window is still open.
What if an estimated service is never performed?
Do not leave an unused service in the estimated 10% group to create extra headroom. For a $2,000 eligible estimate containing an unperformed $200 service, the remaining base is $1,800 and its 110% ceiling is $1,980. If the properly classified actual charges are $2,050, with no other adjustment or valid revision, the comparison excess is $70. Service, category, shopping, provider and actual payment facts still matter.
Does a small APR change always require a new wait?
No. Apply Section 1026.22’s accuracy provisions, rather than treating every movement as inaccuracy. Its ordinary tolerances include one-eighth of a percentage point for regular transactions and one-quarter for qualifying irregular transactions, with additional mortgage provisions that can treat a disclosed APR as accurate. A variable rate alone does not automatically make the transaction irregular. This lesson does not calculate a live APR or replace the rule’s finance-charge and other conditions.
Can the consumer waive the waiting period?
Only under the applicable bona fide personal financial emergency rule, not simply because everyone would prefer an earlier closing. After receiving the required disclosures, the consumer supplies a dated written statement describing the emergency and specifically modifying or waiving the applicable wait. All consumers primarily liable on the obligation must sign, and preprinted waiver forms are prohibited. The initial seven-day wait and final three-day wait have separate provisions. No private emergency or waiver is approved here.
Where can I study the official forms?
The CFPB’s forms-and-samples page links official Loan Estimate and Closing Disclosure forms, samples and annotated materials. Compare the early estimate with the final disclosure, then practise the separate receipt and correction clocks. A sample does not decide whether a particular fee is lawful, whether a loan is approved or when an actual borrower may consummate. This review examined the forms index, not every linked PDF or specialized program.
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Official sources and scope
Sources and identified operative provisions reviewed through October 27, 2026. Timing, receipt, fee comparisons and revisions are read with the official interpretations. The examples state coverage, calendars, category eligibility, receipt and other timing assumptions; they are not a private loan audit, disclosure form or closing-calendar approval. The CFPB forms-and-samples page offers official study materials, but this lesson does not claim a line-by-line audit of every linked form or specialized program.
- PSI Illinois Candidate Information Booklet: National Financing outline
- Regulation Z 1026.2: definitions and business days
- Regulation Z 1026.3: purpose and dollar-threshold exemptions
- Regulation Z 1026.19(e) and (f): covered mortgage disclosure timing
- Regulation Z 1026.22(a)(1): APR as a yearly cost measure
- Regulation Z 1026.23: closed-end rescission
- CFPB Regulation Z: prepayment permission, limits and alternatives
- CFPB July 9, 2026 request for information: mortgage credit disclosures
- CFPB: official TRID forms, samples and annotated disclosures
This is exam preparation, not advice for a specific transaction. State law and the applicable facts control. Our editorial and corrections process explains how to report an issue.