Name
The borrower's legal name.
Mortgage & lending
What is TRID?
TRID stands for TILA-RESPA Integrated Disclosure. It is the federal rule governing what a mortgage lender must tell a borrower about the cost of a loan, and when. TRID sets out two disclosures, the Loan Estimate and the Closing Disclosure, and it defines the timing around both so a borrower sees the numbers before committing rather than at the table.
What TRID replaced
Before TRID, a borrower received four documents from two different laws.
The Truth in Lending Act produced one set. The Real Estate Settlement Procedures Act produced another. They overlapped, they used different terminology for the same figures, and they arrived at different points in the process.
TRID merged them. Two documents replaced four, the language was standardized, and the timing was fixed by rule rather than by lender practice. The rule took effect in October 2015 and the industry still calls the change "Know Before You Owe", which was the regulator's name for it.
The practical result is that a Loan Estimate from one lender can be laid alongside one from another and the lines correspond. That was the point.
The six items that count as an application
TRID defines an application precisely, because receiving one starts the clock. Six pieces of information, and all six are needed.
Income
As stated. Nothing has to be verified for the application to be complete.
Social Security number
Which allows the lender to obtain a credit report.
Property address
The subject property.
Estimated property value
An estimate. An appraisal is not required at this stage.
Loan amount sought
What is being borrowed.
Five of six is not an application. The clock does not start until a lender holds all of them, which makes collecting the sixth a decision rather than an accident. Lenders who collect five and wait are not doing anything improper, but a borrower who has given five and heard nothing may be further from a Loan Estimate than they think.
The two disclosures
The Loan Estimate comes first. It sets out what the loan is expected to cost: the rate, the monthly payment, closing costs, and how the figures could change. It follows the application, and it exists so a borrower can compare lenders before committing to one.
The Closing Disclosure comes at the other end. It sets out what the loan actually costs, in final form, and it arrives before the closing appointment rather than at it.
Both are governed by timing rules set out in the regulation. A lender must issue the Loan Estimate within a defined window after receiving an application, and the Closing Disclosure must reach the borrower a defined period before consummation. Those windows are fixed by federal rule and depend on how the document is delivered, so a borrower should confirm the specific dates with their lender rather than counting.
The two documents are built to be compared. Figures that appear on the Loan Estimate appear again on the Closing Disclosure in the same order, so a borrower can read them side by side and see what moved.
What resets the clock
The part that causes most operational difficulty is not issuing the disclosures. It is what happens when something changes afterwards.
TRID recognizes certain events as valid reasons for a figure to change. A rate lock, a borrower requesting a different product, an appraisal coming in differently, information that turns out to be inaccurate. When one of these happens, a revised disclosure is issued.
Some changes go further and restart the waiting period before closing. The regulation names which ones. Where a late change falls into that category, the closing date moves, and it moves regardless of whether everyone is ready.
This is why lenders treat late changes as a scheduling event rather than a paperwork event. A figure corrected two days before closing may cost a week.
Which specific changes trigger a restart, and how long the resulting period runs, are set out in the regulation. Confirm the current position with your lender or compliance team rather than relying on a summary.
What an affiliated business arrangement disclosure is
An affiliated business arrangement disclosure, sometimes shortened to AfBA or ABA disclosure, is a separate notice telling you that the company referring you to a service provider has an ownership interest in that provider.
The situation it covers is common. A real estate brokerage refers you to a title company, and the brokerage owns part of that title company. A lender refers you to an affiliated appraisal management firm. The referral may be entirely reasonable, and the arrangement may be disclosed precisely because it is allowed. What is not allowed is concealing it.
The disclosure is required under RESPA rather than under TRID, which is why it arrives as its own document rather than as a section of the Loan Estimate. It names the relationship, gives an estimated cost range for the affiliated service, and states that you are generally not required to use that provider.
That last point is the one people miss. A referral to an affiliated company is a referral, not an instruction. There are narrow exceptions where a provider is required, and the disclosure will say so.
What to do with it: read the cost range, and if the service is one you can shop for, get one other quote before accepting the referral. The disclosure exists to make that comparison possible.
What a FACT Act free disclosure is
This one is unrelated to the mortgage documents and gets confused with them because it arrives at the same time.
The Fair and Accurate Credit Transactions Act, usually shortened to FACT Act or FACTA, is a federal law about credit reporting. Among other things, it entitles consumers to obtain their credit report from the nationwide reporting agencies without charge.
The FACT Act free disclosure notice tells you about that right. It commonly appears in a mortgage packet because the lender has just pulled your credit, and in some circumstances a lender is required to inform you of what it obtained and what you are entitled to see.
It is a notice rather than a document you act on. Nothing about your loan depends on it, and nothing is required from you in response.
If you want to use the entitlement, the reports are obtained directly from the reporting agencies rather than through your lender.
What TRID does not do
Four things get attributed to TRID that are not in it.
It does not cap what a lender charges. TRID governs disclosure and timing. Fees themselves are a matter of competition, not of this rule.
It does not apply to every loan. Certain transaction types fall outside it and use different disclosures. A borrower who received something that looks unlike the standard documents has not necessarily been mistreated.
It does not verify anything. Every figure on a Loan Estimate is the lender's own. TRID sets out how they must be presented and how much they may move, not whether they were right at the outset.
It does not stop costs changing. It requires that changes be disclosed, and constrains certain categories of change. A borrower expecting a Loan Estimate to be a fixed quote has misread its purpose.
Where TRID goes wrong in practice
The application definition is misread
Teams treat a partial file as an application, or hold a complete one without recognizing it. Both create timing exposure.
Figures assembled by hand
Numbers arriving from several systems and keyed into one document is where late corrections come from, and a late correction can move the closing date.
Delivery not evidenced
Timing depends on when a document reached the borrower. Where that is not recorded reliably, proving compliance later is difficult.
Changes not logged
A revised disclosure without a recorded reason is hard to defend in an audit, even when the reason was legitimate.
Third-party costs arriving late
A fee that lands after the Closing Disclosure has been issued is the most common cause of a restarted period.
For lenders: TRID as an operational problem
Almost no TRID failure is a failure to understand the rule. Compliance teams know it well. The failures are operational, and they cluster in four places.
Timestamps. Compliance turns on when a document was issued and when it reached the borrower. If those events live in an email client rather than in the file, the evidence is weaker than the practice.
Data entry. Figures keyed from documents into a disclosure introduce a class of error that surfaces late, and late is exactly when a correction costs the most.
Change records. A revised disclosure is defensible when the triggering event is recorded alongside it. Reconstructing the reason afterwards is the difficult version of the same task.
Reconciliation. The Loan Estimate and the Closing Disclosure have to agree on everything that did not legitimately change. Where those two documents are assembled from different sources, the difference is found by a person, usually under time pressure.
None of these are compliance problems in the sense of knowing the rule. They are questions about whether the file holds a reliable record of what happened.
Answers at a glance
Common questions
TRID stands for TILA-RESPA Integrated Disclosure. It is the federal rule combining disclosures previously required separately under the Truth in Lending Act and the Real Estate Settlement Procedures Act into two documents, the Loan Estimate and the Closing Disclosure.
Six items: the borrower's name, income, Social Security number, the property address, an estimate of the property value, and the loan amount sought. A lender holding all six has received an application, and the disclosure timing begins from that point.
The Loan Estimate sets out what a loan is expected to cost and follows the application, so a borrower can compare lenders. The Closing Disclosure sets out the final costs and arrives before the closing appointment. The two are laid out to be read side by side.
Yes, within limits the regulation defines. Certain events allow a figure to change and a revised disclosure to be issued, while other categories are constrained. A Loan Estimate is an estimate governed by rules, not a fixed quote.
It is a notice telling you that the company referring you to a service provider, such as a title company, has an ownership interest in that provider. It names the relationship, gives an estimated cost range, and states that you are generally not required to use that provider.
Generally no. The disclosure exists so you know about the relationship and can shop elsewhere if you want to. There are narrow exceptions where a particular provider is required, and the disclosure will say so if one applies.
It is a notice about your right to obtain your credit report from the nationwide reporting agencies without charge, under the Fair and Accurate Credit Transactions Act. It commonly appears in a mortgage packet because the lender has pulled your credit. Nothing is required from you in response.
No. Certain transaction types fall outside TRID and use different disclosures. Receiving documents that look different from the standard Loan Estimate and Closing Disclosure does not by itself indicate a problem.
Some changes require a revised Closing Disclosure and restart the waiting period before consummation. The regulation defines which changes have that effect. Where one applies, the date moves regardless of whether everyone else is ready.
No. TRID governs what must be disclosed and when, and constrains how much certain figures may move between disclosures. It does not cap fees themselves.
Related terms
Disclosure timing is a data problem
Almost no TRID failure comes from misunderstanding the rule. It comes from figures keyed by hand, delivery that was not evidenced, and changes recorded nowhere. CliQloan, one of the AmitaSoft platforms, generates and tracks TRID, RESPA and ECOA disclosures and keeps a digital evidence log of what went out and when.
Read about CliQloan →