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An MLO realizes at closing that a loan's Annual Percentage Rate (APR) has increased by 0.25% above what was disclosed, triggering a required re-disclosure and new waiting period. The real estate agent, seller, and borrower all agree to waive the waiting period to close on time. The MLO, wanting to accommodate everyone, proceeds to close without re-disclosing and waiting. Which of the following best characterizes the regulatory consequences for the MLO?

Uniform State Test (UST) · 11% of the SAFE examhard

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Correct answer: The MLO violated TRID rules, which is a state and federal compliance failure that could result in disciplinary action regardless of party consent

TRID (TILA-RESPA Integrated Disclosure) rules under Regulation Z require re-disclosure and a new three-business-day waiting period when the APR increases by more than 0.125% (for regular transactions) or certain other triggering changes occur. This waiting period exists specifically to protect consumers and cannot be waived by the parties — including the borrower. The rule is regulatory, not contractual. An MLO who facilitates closing in violation of TRID is engaging in prohibited conduct under federal law, mirrored in state mortgage law, and is subject to disciplinary action. "," is incorrect because consumer protection waiting periods under TRID are non-waivable by parties; consent does not cure the violation. "," is incorrect because the violation exists at the moment of the non-compliant closing — a borrower complaint is not a prerequisite for regulatory action. "s interest was protected by their agreement" is incorrect because MLOs have independent compliance obligations; the lender's responsibility does not eliminate the MLO's individual exposure.

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