CD issued & the 3-day clock
Auto-generated at UWM, requested elsewhere — then TRID timing governs.
Overview
Every gate item is satisfied — the Closing Disclosure can now be issued. Once it reaches the borrower, TRID's three-business-day waiting period begins, and closing cannot happen until it expires.
How the CD gets issued depends on the lender, and the difference matters for how much Emily has to do.
Two paths
UWM — automatic
Once every item on the gate checklist is satisfied, UWM automatically generates the initial CD and sends it to the borrower, which starts the three-day clock. Emily doesn't request anything. Her job is to clear the gate and then confirm the CD actually went out.
Everyone else — request required
Kind Lending, PennyMac, Loan Store, and most other lenders require Emily to submit a request-for-CD form in their portal. The form is the trigger. Important: those portals typically won't let the form be submitted until the same gate items are satisfied — so the checklist still governs, it just doesn't fire automatically at the end.
Know which path your lender is on. The failure mode is assuming automatic when it isn't: the gate clears, Emily moves on, and nobody notices for two days that no CD was ever requested — two days burned off a closing timeline that had no slack. On any non-UWM file, requesting the CD is an explicit task, not something that happens on its own.
The three-day clock
TRID requires the borrower to receive the CD at least three business days before consummation. The lender systems enforce this — you won't be able to schedule a closing that violates it — but understanding it is what lets you plan backward from the closing date instead of discovering a problem.
Practical implication: the CD issue date determines whether the closing date holds. Work backward from the scheduled closing, count back three business days, and that's your deadline for getting the CD out. Miss it and the closing moves — there's no waiver for convenience.
After the CD goes out
- Confirm the borrower received it. A CD sitting unopened in a spam folder is a CD that will cause problems at signing.
- Watch for changes that trigger a re-disclosure. Certain changes after the CD is issued require a corrected CD and can restart the waiting period. If numbers move materially, flag it before it becomes a closing-day surprise.
- Move on to closing coordination — title, figures, and borrower preparation run during this window.
Common pitfalls
Assuming the CD went out
On non-UWM lenders it doesn't go out until requested. Verify, don't assume.
Not planning backward from the closing date
The three-day rule isn't flexible. A CD issued too late moves the closing, which moves the seller's plans, the movers, the rate lock expiration, and everything else.
Late changes that restart the clock
Material changes after CD issuance can require re-disclosure. The later a change lands, the more expensive it is — catch fee and figure problems during the balancing work, not after.
Who to ask if you're stuck
Whether a change requires re-disclosure: Bryce — don't guess on TRID.
CD not generating despite a clear gate: the lender's account executive.
Timeline pressure against the three-day rule: the LO and Bryce, early rather than late.