The Closing Disclosure waiting period
TRID exists so a borrower has time to read the final terms before signing, not at the table. Under 12 CFR 1026.19(f)(1)(ii) the consumer must receive the Closing Disclosure no later than three business days before consummation.
For this waiting period, Saturdays count as business days; Sundays and legal public holidays do not.
Worked example: the lender hand delivers the Closing Disclosure on Monday, October 5. The three business days are Tuesday, Wednesday and Thursday, so the earliest closing is Thursday, October 8. Tuesday and Wednesday are fewer than three business days. Monday, October 12 belongs to the mailing scenario, where receipt is presumed three business days after mailing and the count starts later.
What restarts the clock
Under 12 CFR 1026.19(f)(2)(ii) only three changes restart the three-business-day waiting period:
- the APR becomes inaccurate beyond tolerance
- the loan product changes
- a prepayment penalty is added
Everything else needs only a corrected Closing Disclosure at or before consummation, with no new waiting period. An extra $500 seller credit toward closing costs, a $25 increase in the recording fee, and a change of the buyer's hazard insurance carrier do not restart it.
The trap is assuming any fee change restarts the clock. It does not, and if it did, closings would be nearly impossible to schedule.
Georgia rule: the licensee's closing statement duty
O.C.G.A. 43-40-25(b)(20) makes it an unfair trade practice to fail "to timely ensure that his or her client or customer receives a copy of the closing statement from a real estate transaction if the closing statement is provided to the licensee at closing." Rule 520-1-.10(3) separately requires giving a copy of any document to anyone who signs it.
So a salesperson handed the closing statement at the table cannot say the attorney delivers everything — the statute puts this duty on the licensee. There is no filing of closing statements with the Georgia Real Estate Commission within 30 days; instead, closing statements are kept in the broker's file for three years and produced to Commission agents on reasonable request under Rule 520-1-.10(4). And the duty is not conditioned on a written request from the seller.