Here is a comprehensive list of questions a mortgage loan officer (LO) might ask their broker about the Closing Disclosure (CD), along with detailed explanations for each:

📅 1. When must the Closing Disclosure be delivered to the borrower?

Explanation:
The CD must be delivered at least 3 business days before consummation (signing). LOs need to understand this to avoid delays in closing.

✍️ 2. Who is responsible for preparing and delivering the CD—broker, lender, or escrow?

Explanation:
Usually, the lender prepares and delivers the CD, but LOs may ask this when working with different wholesale lenders, each with unique processes.
In some cases, settlement agents (escrow/title) handle seller CDs.

🔁 3. When do I need to issue a revised CD?

Explanation:
A revised CD is required when certain changes occur after the initial CD is issued, including:

  • APR increases beyond tolerance
  • Loan product changes
  • Addition of a prepayment penalty
    These trigger a new 3-day waiting period.

⚠️ 4. What types of changes DO NOT require a new 3-day waiting period?

Explanation:
LOs need to know which corrections can be made up to or at closing:

  • Clerical errors
  • Seller concessions
  • Minor fee updates
    These don’t reset the 3-day clock.

🧾 5. What fees need to be double-checked for tolerance violations?

Explanation:
LOs must review:

  • 0% tolerance fees (lender charges, appraisal, credit report)
  • 10% cumulative tolerance (title, escrow, recording)
    Brokers may be liable for cures if disclosures aren’t accurate.

📊 6. How do lender credits and seller credits show on the CD?

Explanation:
LOs often ask how these are itemized:

  • Seller credits appear in Section L
  • Lender credits go in Section J or under “Paid by Others”
    Correct display impacts borrower cash to close.

💵 7. What happens if the CD is delivered late?

Explanation:
If the CD is not received 3 business days before closing, the signing must be rescheduled. LOs want to avoid last-minute delays and funding issues.

🔐 8. Can I email the CD, and does the borrower need to sign it?

Explanation:
TRID allows electronic delivery (with e-sign consent), and signatures are not required, but proof of receipt is required.
If mailed, receipt is presumed after 3 business days.

🧮 9. How is “Cash to Close” calculated, and what affects it?

Explanation:
Loan officers need to understand how:

  • Down payment
  • Prepaids
  • Closing costs
  • Credits
    impact this figure so they can explain it clearly to the borrower.

📈 10. How do I explain the “Projected Payments” section to a client?

Explanation:
This section outlines:

  • Principal & interest
  • Mortgage insurance (if applicable)
  • Estimated escrow (taxes & insurance)
    Borrowers often find this confusing, and LOs need a clear way to walk them through it.

🏠 11. Where do prepaid taxes and insurance appear on the CD?

Explanation:
They are shown in Section F (Prepaids) and Section G (Initial Escrow Payment at Closing). LOs ask this when reviewing tax prorations and insurance escrows.

📝 12. What if the escrow company made a mistake on the CD? Am I liable?

Explanation:
If the LO or broker provided incorrect fee info to escrow, they may be responsible for curing tolerance violations or delayed closings.

🔄 13. Can the borrower waive the 3-day CD waiting period?

Explanation:
Only under a “bona fide personal financial emergency”—very rare and must be documented in writing. LOs often ask when clients are in a hurry to close.

💰 14. What happens if the CD lists a higher APR than the LE?

Explanation:
If the APR exceeds allowable tolerance from the LE, the CD must be reissued, and the 3-day clock restarts. LOs want to know how to avoid this and ensure accuracy.

🔍 15. How do I explain the “Loan Costs” and “Other Costs” sections to a client?

Explanation:
LOs often ask how to break down:

  • Loan Costs: Lender fees, services borrower did and did not shop for
  • Other Costs: Taxes, insurance, title, HOA, etc.
    This helps build trust with clients.

⏱️ 16. What are common last-minute issues that delay CD signing or funding?

Explanation:
LOs want to avoid:

  • CD not acknowledged in time
  • Missing wire instructions
  • Errors in credits or fees
  • HOI or insurance binder not received
    Proactively asking about this helps avoid last-minute chaos.

📂 17. What’s the difference between the borrower CD and the seller CD?

Explanation:

  • Borrower CD: Details buyer’s costs and cash to close
  • Seller CD: Reflects seller proceeds, commissions, and closing costs
    Some LOs want to clarify responsibilities for explaining or distributing both.

🔁 18. Can I correct errors on the CD after closing?

Explanation:
Yes, a post-closing corrected CD may be required. LOs should understand when this is necessary and who is responsible for reissuing.

📉 19. What if a borrower signs but doesn’t fund—does the CD still stand?

Explanation:
Yes, but a non-funded loan typically voids the transaction. If the file is reactivated, a new CD and waiting period may apply.

📋 20. How do I ensure consistency between the LE and CD?

Explanation:
LOs should compare both forms side by side:

  • Watch for fee changes
  • Confirm APR and cash to close
  • Identify tolerance violations
    This ensures compliance and avoids legal exposure.

Disclaimer:
The questions and answers provided are for general guidance only and may not cover all details or apply to every situation. If anything is unclear or you need further clarification, please visit car.org for official resources and the most up-to-date information from the California Association of REALTORSŽ.

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