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When must the bank provide the Loan Estimate and the Closing Disclosure be provided for the permanent phase under the TRID rule?

My bank received an application for both the construction loan and permanent financing and will conduct separate closings and provide separate disclosures for each phase. When must the bank provide the Loan Estimate and the Closing Disclosure be provided for the permanent phase under the TRID rule?

The bank must provide the Loan Estimate within 3 business days of receipt of the application and the Closing Disclosure upon completion or near-completion of the construction phase if a revised Loan Estimate is not needed. (See the Consumer Financial Protection Bureau guidance in the 2017 TILA-RESPA Rule: Detailed Summary of Changes and Clarifications (December 2019)

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