TRID on a refinance: the 7-day rule, the CD clock and the payoff table

A refinance cannot close sooner than seven business days after the Loan Estimate, and the Closing Disclosure must be received three business days before signing; its payoff table is where a no-cost refi shows its true price.

Two clocks that set your earliest closing date

Once a lender has your name, income, Social Security number, the property address, an estimated value and a loan amount, it has an application and must deliver a Loan Estimate within three business days. Before you state that you intend to proceed, the only fee it may collect is a reasonable credit-report charge — so a lender that wants an appraisal deposit with the application is jumping the gun. The LE starts a second clock: consummation may not occur until seven business days after the LE is delivered or placed in the mail. A rate locked after the initial LE requires a revised LE within three business days of the lock, but that revision does not restart the seven-day count.

The Closing Disclosure must be received three business days before signing, with business days counted as every day except Sundays and federal holidays. If it is mailed, receipt is presumed three business days later, which is why lenders push e-signature consent. A new three-day wait is required only if the APR moves more than 1/8 of a point (1/4 on irregular loans), the loan product changes, or a prepayment penalty is added; a corrected fee does not reset the clock.

Reading a refinance CD

Without a seller, lenders use the alternative Closing Disclosure with a Payoffs and Payments table instead of a summaries-of-transactions page. That table lists your old mortgage payoff, any liens or debts paid through closing on a cash-out loan, and produces the “cash to close” figure — positive if you bring money, negative if you receive it. Three lines deserve a pencil: Section A (origination charges and points), the Lender Credits line at the bottom of Section J, and the loan amount on page one. A “no-closing-cost” refinance shows up as either a large lender credit paired with a higher rate, or a loan amount visibly above your payoff.

Also compare the Total Interest Percentage and the “In 5 years” box with your current loan’s remaining schedule. The CD does not show your old escrow refund or the per-diem interest you will owe on both loans during the rescission week; ask for those numbers separately.

Tolerances on a refinance

Lender fees, fees paid to lender affiliates and fees for services you were not allowed to shop for cannot rise at all from the LE. Recording fees and third-party services you chose from the lender’s written list may rise up to 10% in aggregate. Prepaid interest, escrow deposits and anything from a provider you picked on your own carry no tolerance. If a lender issues a revised LE citing a “changed circumstance,” it must do so within three business days of learning the reason — a revised LE issued the day before the CD, raising the appraisal fee, deserves a question.

Home equity lines of credit are not TRID loans; they come with their own early disclosures under §1026.40, so a HELOC quote cannot be compared line by line with a cash-out LE.

What to check

• Get same-day Loan Estimates from at least two lenders and compare Section A plus the rate, the lender credit and the loan amount together.
• Count the seven business days from the LE and the three from CD receipt; your funding date is later still on a primary residence because of rescission.
• On the CD, check that the Payoffs and Payments table uses a payoff good through the funding date, not the signing date.
• If a fee in the zero-tolerance group rose between LE and CD, ask for the changed-circumstance documentation or a cure at closing.

Frequently asked questions

Why does my refinance Closing Disclosure show a different cash-to-close than my Loan Estimate?

Usually because of prepaid interest and the escrow deposit, which move with the closing date and carry no tolerance, or because the final payoff from your old servicer came in higher than the estimate used on the LE. Compare the two page-by-page: fees in Section A, B and C that rose beyond tolerance must be refunded, while changes in payoffs, prepaids and escrow are legitimate.

Can I close a refinance faster than the TRID timelines?

Only by waiving the waiting periods for a bona fide personal financial emergency, in a written statement you draft yourself. The seven-day LE wait and the three-day CD wait both apply, and lenders rarely accept waivers outside a documented emergency such as an imminent foreclosure sale. Streamline refis do not shorten these periods.

The rule in full: TRID: the Loan Estimate and Closing Disclosure. The borrower profile: Refinancing homeowners. Related guides: Rate-and-term refinance: when it pays, how to compute the break-even · Cash-out refinance: limits, costs and when it is the wrong tool · Closing costs explained: what is negotiable, what is not · Pre-approval vs pre-qualification: what sellers actually respect.

Other federal rules for refinancing homeowners

TILA / Reg Z · RESPA · ECOA · Fair Housing Act · HMDA · SAFE Act / NMLS · ATR / QM · HOEPA · HPA / PMI · Servicing rules · FCRA · Flood insurance · MARS rule · SCRA · LO compensation

TRID disclosures for other borrowers

First-time buyers · Conventional borrowers · Veterans · Self-employed · Investors · Retirees · Bad credit · Foreign nationals · Physicians · Heroes · Rural buyers · Condo & second home