The biggest win for mortgage lenders in the CFPB’s proposal to clarify certain aspects of its integrated disclosure rule is the apparent closing of what’s known as the TRID’s “black hole.” The black-hole problem stems from the fact that, currently, the integrated disclosure rule requires that the creditor deliver or place in the mail the loan estimate no later than the third “general” business day after receipt of the consumer’s application, and the borrower must receive the final revised LE no later than four business days prior to consummation. Once the closing disclosure has been issued, the LE can no longer be provided. If there is a valid change of circumstance that delays closing and results in a fee change,...