TRID deadlines for mortgage brokers

The deadlines

• The application exists once you have six things: the borrower's name, income, Social Security number, the property address, an estimated value, and the loan amount (Reg Z §1026.2(a)(3)(ii)). The clock starts then, however the information came in.
• Loan Estimate: delivered or mailed within three business days after the application (§1026.19(e)(1)(iii)). Until then, don't require documents to verify the application.
• Fees: nothing but a bona fide credit report fee until the borrower has the LE and says they intend to proceed (§1026.19(e)(2)(i)).
• Rate lock after the LE: a revised LE within three business days (§1026.19(e)(3)(iv)(D)).
• Revised LE: received at least four business days before closing, and never on or after the day the CD is given (§1026.19(e)(4)(ii)).
• Closing Disclosure: received at least three business days before closing (§1026.19(f)(1)(ii)).
• Earliest closing: no sooner than seven business days after the LE went out, and three after the CD was received.

Two kinds of business day

Reg Z uses two definitions (§1026.2(a)(6)), and mixing them up is the usual mistake:

• General: the days your office is open for business. Used for the three-day LE deadline, the lock, and intent to proceed.
• Specific: every day except Sundays and federal public holidays. Saturdays count. Used for every waiting period before closing and for when mail is "received".

The mailbox rule: a disclosure handed over in person is received that day. Mailed or emailed, it's treated as received three specific business days after it was sent, unless you can show when it actually arrived (an e-sign acknowledgment, for example).

A worked example

An office open Monday to Friday. The application is complete on Tuesday, October 20, 2026.

Move the closing to Thursday, October 29 and it's a day too early, whatever date the CD went out.

Who sends what in the broker channel

Most wholesale lenders issue the LE and CD themselves; some require the broker to issue the initial LE. Either way, the deadline runs from the broker's application date, so the file has to reach the lender in time for the lender to meet it. Check each lender's broker guide.

Track it without a spreadsheet

OpenLOS keeps a TRID clock on every loan. It starts the clock the first time a save completes the six pieces. It shows every deadline above, using your office's days and the federal holiday calendar, and flags the most urgent item on the pipeline. It also warns when a planned closing is too early. Try it in the demo, or read how it works, including what it doesn't cover yet: changed circumstances other than a lock, CD corrections, tolerance cures, rescission, and state rules.

A working aid, not legal advice. Check deadlines against your lender's disclosure records and your own compliance review.