The latest wave in the tsunami of rulemakings from the CFPB is the pending integrated disclosure rule under the Truth in Lending Act and the Real Estate Settlement Procedures Act. And just the timing aspects related to providing the consumer the loan estimate and the closing disclosure could cause havoc, a top industry attorney warned recently. According to Phillip Schulman, a partner in the Washington, DC, office of the K&L Gates law firm, the biggest problem with the TILA/RESPA Integrated Disclosure (TRID) rule has to do with the timing requirements. “You have to give the loan estimate to the borrower within three business days of receiving the application, and no sooner than seven days before consummation or closing of the ...