By what date must a lender provide the Closing Disclosure if a loan application is submitted on August 3 and closing is set for September 21?

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To determine the correct date by which a lender must provide the Closing Disclosure, it's essential to understand the regulations outlined in the TILA-RESPA Integrated Disclosure Rule. According to these regulations, a lender is required to provide the Closing Disclosure to the borrower at least three business days prior to the closing of the loan.

In this scenario, the loan application is submitted on August 3, and the closing date is set for September 21. To find the latest possible date for the lender to provide the Closing Disclosure, you must count backward three business days from the closing date.

Considering that September 21 is the closing date, if we subtract three business days, we arrive at the following timeline:

  • September 21 (closing date)

  • September 20 (1 business day prior)

  • September 19 (2 business days prior)

  • September 18 (3 business days prior)

Thus, September 18 falls three business days before the closing date of September 21. This confirms that the Closing Disclosure must be given to the borrower by September 18, ensuring they have sufficient time to review it before closing. This choice aligns with regulatory requirements for timely disclosures in real estate transactions.

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