Comment from Jackson Miller Law, LLC

Jackson Miller Law, LLCOtherBusiness
Summary: The commenter, a real estate closing attorney/title agent, expresses concerns regarding the current practices of lenders who provide final closing documents too late for adequate review. They advocate for a requirement that final document packages be received by title companies at least one full business day prior to signing.
As a real estate closing attorney/title agent in South Carolina, I do not have major issues with the TRID timing requirements. What I do have an issue with is that lenders are issuing the final CDs to Buyers/Borrowers without final balancing (and sometimes without having a Clear to Close from their underwriter) with the closing attorney/title company and then not getting the documents to the closing attorney/title company with enough time for the Buyers/Borrowers to review them and having to rush through signing everything. Many Buyers/Borrowers want to see the closing documents before they ever come in to sign. It also makes it hard for the closing attorney/title company to review the documents prior to sitting down with the Buyers/Borrowers to check for errors, so when there is an error in the documents, it is caught at the last minute which causes more stress and anxiety on the Buyers/Borrowers. In my opinion, final document packages should be required to be received by the closing attorney/title company at least 1 full business day prior to the signing of the closing documents. I feel this was the intention of the CFPB with the 3 day rule but many times the lenders are not providing documents until late in the afternoon the day before, or the morning of closing, which makes it difficult to set appointments and ends up with everything very last minute.

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