Capital Mortgage Source

Last updated: February 25, 2026

This document is the definitive step-by-step guide for every mortgage transaction originated at Capital Mortgage Source. It covers every phase from first borrower contact through post-closing. Follow these procedures on every loan, every time — they exist because deviating from process is the most common source of compliance violations, blown closings, and unhappy borrowers. Oregon-specific requirements are called out explicitly throughout.


Last updated: 2026-02-25 | Owner: Operations Manager


Phase 1: Pre-Qualification#

1.1 Initial Borrower Contact — What to Gather, What to Say#

The first conversation sets the tone for the entire relationship. Your goals in the first call are:

  1. Assess basic eligibility (credit, income, down payment)
  2. Understand what the borrower is trying to accomplish
  3. Set expectations for the process and timeline
  4. Schedule a follow-up with a complete application if they're a viable lead

What to gather on first contact:

Category Information to Collect
Identity Full legal name, date of birth, contact info
Property Purchase or refi? Target price/current value? Address if known
Occupancy Primary residence, second home, or investment?
Income Employment type (W2, self-employed, retired)? Rough annual income?
Assets Estimated down payment or equity? Source of funds?
Credit Have they checked their credit recently? Estimated range?
Timing How soon are they looking to close?
Agent Are they working with a real estate agent?

What NOT to say on the first call:

  • Do not quote rates. You don't have their file yet.
  • Do not make verbal pre-approval commitments.
  • Do not discuss loan amount until you've reviewed income documentation.
  • Do not ask questions that could constitute discriminatory inquiry (see Compliance Guide, Section 2).

Script note: See Templates & Scripts, Section 4 for the recommended initial inquiry response email to send after the call.


1.2 Credit Authorization Requirements#

Oregon and federal law require written authorization before you pull credit. This is not optional. Pulling credit without written authorization is a violation of the Fair Credit Reporting Act (FCRA) and Oregon consumer protection law.

Authorization process:

  1. Send the credit authorization form to the borrower via Arive's borrower portal (or email if portal hasn't been set up).
  2. Do not pull credit until you have a signed, dated authorization in hand.
  3. Log the authorization receipt in Arive notes immediately.
  4. Retain the signed authorization in the loan file.

What counts as valid authorization:

  • Signed 1003 (the loan application itself contains credit authorization language) — this is the most common method.
  • Separate signed credit authorization form.
  • eSign via Arive's disclosure portal is acceptable.

Joint borrowers: Each borrower must provide separate authorization. One spouse cannot authorize a pull for the other.

FCRA note: You may only pull credit for a "permissible purpose." For mortgage origination, that purpose is a borrower-initiated application. If a borrower withdraws their application, you may not pull additional credit.


1.3 Income and Asset Documentation Checklist#

Gather this documentation before running numbers. Incomplete documentation leads to bad pre-quals that fall apart in underwriting.

W-2 Employed Borrowers

  • Most recent 2 years of W-2s (from every employer)
  • Most recent 30 days of pay stubs (all jobs)
  • Most recent 2 months of bank statements (all accounts, all pages — no missing pages)
  • Government-issued photo ID (front and back)
  • Social Security number (for credit pull authorization)
  • If using RSU/bonus income: 2-year average required; bonus must be likely to continue

Self-Employed Borrowers

  • Most recent 2 years of personal tax returns (all schedules, all pages)
  • Most recent 2 years of business tax returns (if applicable)
  • Year-to-date Profit & Loss statement (CPA-prepared preferred)
  • Business bank statements — most recent 3 months
  • Business license or CPA letter confirming 2-year self-employment history
  • Most recent 2 months personal bank statements (all accounts, all pages)
  • Government-issued photo ID

Retired / Fixed Income Borrowers

  • Social Security award letter (within 12 months)
  • Pension award letter showing monthly amount
  • Most recent 2 months bank statements
  • Most recent tax returns if any taxable income
  • Government-issued photo ID

Asset Documentation Notes

  • Bank statements must include all pages. "Page 3 of 7" missing is a condition. Download the full statement.
  • Large deposits (typically > 50% of monthly qualifying income) require a letter of explanation and source documentation.
  • Gift funds require a gift letter from donor + proof of transfer. See agency guidelines for timing.
  • Retirement account statements: only 60-70% of vested balance typically counts (depending on investor).

1.4 Pre-Qual vs. Pre-Approval — CMS Standard#

These terms are used interchangeably in the market, but they are not the same thing. CMS uses them precisely.

Pre-Qualification Pre-Approval
Credit pulled Soft pull only (or none) Hard pull — written authorization required
Income verified Stated only Documentation reviewed
Commitment level Low — preliminary estimate Higher — pending appraisal and final UW
LOs must disclose This is not a commitment to lend This is not a commitment to lend
Realtors accept it? Increasingly no — in competitive markets Usually yes
When CMS issues it Initial screening only After full doc review + credit pull

CMS Policy: Issue pre-qualification letters only for initial borrower confidence. For any offer situation in a competitive Oregon market, always push to a full pre-approval before the borrower writes an offer. A pre-qual that falls apart in underwriting wastes everyone's time and damages your reputation with the realtor.

Pre-approval letter language: The letter must include language stating it is not a commitment to lend and is subject to satisfactory appraisal, title, and final underwriting review. Use the CMS pre-approval letter template available on the CMS website.


1.5 Entering the File in Arive — Required Fields and Naming Conventions#

Lender selection happens before you create the Arive file. CMS is a mortgage broker — you originate loans through wholesale lenders, not directly. Before creating a file, determine which lender you plan to use for this borrower's scenario. Refer to the CMS website for the current approved lender roster and AE contact information. Lender choice affects program availability, pricing, and submission workflow.

A file that isn't in Arive doesn't exist. Create the Arive file on first contact, not when you decide the borrower is viable.

CMS File Naming Convention:

[LastName]-[FirstName]-[Loan Type]-[YYYYMM]

Examples:

  • Johnson-Sarah-Conv-202603
  • Martinez-Carlos-FHA-202603
  • Williams-Robert-VA-202603

Never use: Borrower SSN, middle names, initials only, or loan numbers before they're assigned.

Required fields at pre-qual stage:

  • Borrower full legal name (as it appears on government ID)
  • Co-borrower name (if applicable)
  • Borrower date of birth
  • Borrower SSN (required for credit pull)
  • Property address (or "TBD" for purchase pre-approvals)
  • Loan purpose (purchase / refinance / cash-out refinance)
  • Loan type (Conventional / FHA / VA / USDA)
  • Occupancy type
  • Estimated loan amount
  • Estimated property value / purchase price
  • Referral source (how did this borrower find CMS?)
  • Assigned LO name
  • File creation date

Notes discipline: Log a note immediately when the file is created. Minimum entry: "File created. Initial borrower contact [date]. Purpose: [purchase/refi]. Estimated [loan type/amount]. Next step: [specific action]." This note is your timestamp and your liability protection.


Phase 2: Loan Application (1003)#

2.1 Taking the Application — What Every Field Means#

The Uniform Residential Loan Application (URLA / Fannie Mae Form 1003, updated 2021) is the legal instrument of the mortgage transaction. Every field matters. Incomplete or inaccurate 1003s are a primary source of underwriting conditions and potential fraud risk.

Section-by-section overview:

Section 1 — Borrower Information Full legal name must match government ID exactly. Date of birth. SSN. Marital status. Number of dependents (ages, not names). Citizenship status. Contact info.

Section 2 — Financial Information (Assets and Liabilities) Every asset must be sourced and verified. Every liability must match the credit report. If there are liabilities on the credit report not reflected in the 1003, that's a discrepancy — add them and explain. Do not coach borrowers to omit liabilities.

Section 3 — Financial Information (Real Estate) Current real estate holdings, rental income (if any), current mortgages. REO properties must be disclosed fully.

Section 4 — Loan and Property Information Loan purpose, property address, legal description (can be added later), occupancy, loan type, loan amount. This section must be accurate — inaccuracies here can trigger re-disclosure requirements.

Section 5 — Declarations Borrower confirms whether they've had prior foreclosures, judgments, delinquencies, outstanding lawsuits, co-signed obligations. Every "yes" requires an explanation letter. Do not tell borrowers what to answer — ask the question neutrally and document their response.

Section 6 — Acknowledgments and Agreements Borrower acknowledges intent, accuracy of information, authorization for credit pull. This is where written credit authorization lives in the 1003.

Section 7 — Military Service (VA borrowers) Active duty, discharge type, disability status. Impacts VA funding fee and entitlement.

Section 8 — Demographic Information (HMDA) Ethnicity, race, sex. Borrower has the right to decline. LO should record "information not provided" if declined. This data is for HMDA reporting — it does not affect loan decisions and must be kept separate from the credit decision.


2.2 Required Disclosures at Application — The 3-Day TRID Rule#

This is the single most important compliance requirement in mortgage origination. Read it carefully.

Under TRID (TILA-RESPA Integrated Disclosure Rule, implemented by Regulation Z and Regulation X), you must deliver the Loan Estimate (LE) to the borrower within 3 business days of receiving a completed application.

Six-element trigger for a "complete application" (CFPB definition):

  1. Borrower name
  2. Borrower income
  3. Borrower Social Security number (to pull credit)
  4. Property address
  5. Estimated property value
  6. Loan amount sought

Critical: Once you have all six elements, the 3-day clock starts — regardless of whether you've called it an "application" yet. Pre-qualification worksheets that collect all six elements trigger the LE requirement. Be intentional about when you collect all six.

Business day definition for LE: All calendar days except Sundays and federal public holidays.

Delivery rules:

  • If delivered electronically (email): 3-day clock assumes receipt on the day of delivery plus 3 business days (i.e., borrower has 3 days to receive it before it's assumed received).
  • If mailed: Add 3 additional days for mail delivery assumption (6 days total).
  • Best practice: Use Arive's disclosure portal for electronic delivery with confirmation tracking.

The LE is issued by the wholesale lender — not generated by CMS. As a mortgage broker, CMS coordinates the disclosure process but the lender executes it. The LO's responsibility is to ensure the lender sends the LE within the 3-business-day window, track borrower receipt confirmation, and monitor TRID deadlines. Use Arive to log and track disclosure milestones. See the Arive Training Guide, Section 4 for disclosure tracking workflow.

What the LE must show:

  • Loan terms (amount, rate, whether fixed or adjustable)
  • Projected payments (PITI + PMI if applicable)
  • Closing costs (itemized)
  • Cash to close
  • APR
  • Three comparison figures (total interest percentage, in 5 years, APR)

See Compliance Guide, Section 1 for complete TRID details including tolerance buckets and re-disclosure triggers.


2.3 Uploading Documents to Arive — File Organization Standard#

Arive's document management is your filing cabinet. Organized files close faster. Disorganized files get conditions.

CMS Document Organization Structure in Arive:

[Borrower File]
├── Application
│   ├── Signed 1003
│   ├── Credit Authorization
│   └── Initial TRID Disclosures (LE + supporting)
├── Income
│   ├── Pay Stubs
│   ├── W-2s (Year 1, Year 2)
│   └── Tax Returns (Year 1, Year 2)
├── Assets
│   ├── Bank Statements (Bank Name, Month)
│   └── Investment/Retirement Statements
├── Property
│   ├── Purchase Agreement (if purchase)
│   ├── Appraisal
│   └── Title/Escrow Documents
├── Credit
│   └── Tri-Merge Credit Report
├── Conditions
│   ├── UW Conditional Approval
│   └── Condition Responses (labeled by condition)
└── Closing
    ├── CD (Final)
    ├── Closing Package
    └── Funding Documents

Document Naming Convention:

[DocumentType]-[BorrowerLastName]-[Date]-[Version]

Examples:

  • W2-Johnson-2024-v1.pdf
  • PayStubs-Johnson-20260201-v1.pdf
  • BankStmt-Johnson-Chase-2026Jan-v1.pdf
  • PurchaseAgreement-Johnson-20260215-v1.pdf

Version control: If a borrower re-sends a document (e.g., updated pay stub), upload the new version as v2, do not delete v1. The original document is part of your audit trail.

Never upload: Password-protected PDFs. Arive cannot parse them and underwriters will condition on it. If a borrower sends a password-protected bank statement, ask them to download and re-upload without password protection.


2.4 Ordering the Appraisal — When and How#

CMS is a mortgage broker. Appraisals are ordered through the wholesale lender — not directly by CMS. The LO's job is to submit the appraisal request to the lender, track status, receive the completed report through the lender's portal, and upload a copy to Arive.

When to request the appraisal:

  • Purchase transactions: Submit the request to the lender after the purchase agreement is executed and the borrower has acknowledged the LE. Do not request before borrower acknowledgment.
  • Refinances: Submit after the borrower has acknowledged the LE and expressed clear intent to proceed.
  • FHA/VA: The lender will assign an appraiser from the approved FHA/VA roster. Do not attempt to select an appraiser.

How to request through the lender:

  • Contact the lender's AE or submit through the lender's portal (per each lender's process)
  • Provide: property address, borrower contact info for access scheduling, and any access instructions
  • The lender manages the appraisal vendor relationship — you coordinate with the lender, not directly with any appraisal management company
  • You cannot communicate directly with the appraiser about value
  • You cannot suggest or pressure for a specific value result (Appraisal Independence Requirements, AIR)

Tracking appraisal status:

  • Log the appraisal request date and lender order confirmation in Arive notes
  • Track status through the lender's portal or by contacting the AE
  • When the appraisal report is available through the lender's portal, download it and upload a copy to the Property folder in Arive immediately
  • Note the appraised value in the Arive file

If the appraisal comes in below purchase price:

  • Notify the borrower immediately
  • Discuss options: renegotiate purchase price, borrower pays gap in cash, contest the appraisal (rebuttal through the lender), or terminate the transaction
  • Document every conversation in Arive notes
  • Contact your Operations Manager if guidance is needed on the rebuttal process

2.5 Submitting to Processing#

LO → Processor handoff is a defined handoff, not a casual email. The LO is responsible for ensuring the file is complete before submission. Incomplete files that go to processing slow down the entire operation.

Pre-submission LO checklist:

  • Signed 1003 (fully completed, no blank required fields)
  • Credit authorization on file
  • LE issued and acknowledged (or 3-day window documented)
  • Full income documentation uploaded and named correctly
  • Asset documentation uploaded (all pages)
  • Purchase agreement uploaded (if purchase)
  • Property address confirmed and entered in Arive
  • Loan type and program confirmed
  • Notes log updated with full file history
  • Arive file status updated to "Processing"

Submission note format in Arive:

[Date] — File submitted to processing. LO: [Name]. 
Income: [W2/Self-Employed]. Docs complete: [Yes/No — note any gaps]. 
Rate locked: [Yes/No — if yes, lock expiration date]. 
Expected closing date: [Date]. Notes: [Anything unusual about this file].

Phase 3: Processing#

3.1 Processor Handoff — What LO Provides, What Processor Owns#

What the LO owns through closing:

  • Borrower relationship and communication
  • Condition resolution that requires borrower action (LOE letters, additional documentation)
  • Rate lock decisions
  • Appraisal issues
  • Pipeline management and timeline oversight

What the processor owns:

  • File organization and completeness
  • Ordering title, escrow coordination (purchase transactions)
  • Condition clearing for items within the file (verification of employment, flood cert, etc.)
  • Pushing the file to underwriting when ready
  • Keeping the LO informed of status changes

What neither can do alone:

  • Make underwriting decisions (that's UW)
  • Override a lender's conditions
  • Guarantee a specific closing date without UW approval

3.2 Condition Clearing Workflow in Arive#

Every conditional approval from an underwriter comes with a conditions list. Managing these conditions systematically is what separates fast closings from dragged-out nightmares.

Condition tracking in Arive:

  1. When the conditional approval arrives, upload it to the Conditions folder immediately.
  2. Create a condition log — either in Arive's task system or in a notes entry — listing every condition, who is responsible, and the status.
  3. Assign conditions: LO-required (borrower LOE, additional docs) vs. processor-required (VOE, insurance binder, etc.)
  4. Update condition status in Arive as each is resolved.
  5. Never submit partial condition packages. Submit all resolved conditions at once when the package is complete.

Condition types you'll see:

Condition Type Owner Resolution
Letter of Explanation (LOE) LO / Borrower LO drafts, borrower signs
Employment Verification (VOE) Processor Processor orders directly
Additional Pay Stubs LO / Borrower Borrower provides through portal
Updated Bank Statements LO / Borrower Borrower provides through portal
Gift Letter LO / Borrower LO sends template, borrower signs
HOA Contact for Condo Processor Processor contacts HOA
Flood Cert Processor Ordered automatically in most systems
Insurance Binder LO / Borrower LO coordinates with borrower's insurance agent
Title Commitment Processor Title company provides
Appraisal Conditions LO / Lender LO works with lender AE to resolve appraisal conditions

3.3 Communicating with Borrowers During Processing#

The #1 complaint borrowers have about loan officers is not hearing from them. Processing can feel silent to a borrower. Your job is to prevent that silence from creating anxiety.

CMS communication standard during processing:

  • Minimum weekly update: Every borrower gets a status call or email at least once a week during processing, even if nothing has changed. "Nothing has changed — we're in queue with the lender" is a valid and valued update.
  • Immediate notification for: Any request for additional documentation, any delay that affects closing date, any appraisal issues, any underwriting issues.
  • Do not: Wait for the borrower to call you. If they're calling to check status, you've already failed the communication standard.

See Templates & Scripts for the weekly update email template.


3.4 Rate Lock — When to Lock, How to Lock in Arive#

Rate lock decisions are LO responsibility. The processor does not lock. The processor does not advise on rate. The LO makes this call in consultation with the borrower.

When to lock:

  • When the borrower has a ratified purchase agreement
  • When the closing date is predictable (within the lock period)
  • When the borrower expresses intention to proceed (for refinances)
  • Not before: You have a complete application and LE has been acknowledged

Lock period selection:

  • 30-day locks: Use when you have a clear 21-day processing timeline and closing is confirmed
  • 45-day locks: Standard for most purchase transactions with normal processing timelines
  • 60-day locks: Use for complex files (self-employed, condo, new construction), FHA 203(k), short-sale transactions
  • Longer locks cost more in price — explain the cost/benefit to borrowers

How to lock in Arive:

  1. Navigate to the loan file → Pricing/Lock tab
  2. Confirm current rate with lender pricing engine (linked within Arive)
  3. Select product, term, and lock period
  4. Submit lock request
  5. Confirm lock confirmation from lender appears in Arive (or email confirmation from lender — upload to file)
  6. Log the lock in Arive notes: "Rate locked [date] at [rate]%, [product], [lock period] days. Expiration: [date]. Lender: [lender name]."
  7. Notify borrower immediately — see rate lock confirmation email template in Templates section

Lock expirations: You are responsible for monitoring lock expiration dates. Set a reminder 10 days before expiration. If the closing is going to miss the lock, you have two options:

  1. Extension: Contact lender to extend the lock (typically costs price adjustment)
  2. Re-lock: In some cases, relocking at current market rates may be better or required

Never let a lock expire unmonitored. An expired lock with a float-up in rates can blow a purchase transaction.


3.5 Common Processing Delays and How to Avoid Them#

Delay Root Cause Prevention
Missing document pages Borrower sends only recent statement, not all pages Always specify "all pages, no exceptions" in doc request
Unverifiable large deposits Borrower deposited cash or undocumented funds Catch this at pre-qual; document sources before processing
Employment verification fails Borrower changed jobs without telling LO Ask explicitly: "Have you changed jobs, had any changes to your pay, or expect any changes before closing?" every touchpoint
Appraisal below value Market shift or borrower expectations Set realistic expectations in pre-qual; don't over-promise on value
Missing insurance binder Borrower forgets to contact insurance agent Put this on the closing checklist; send reminder 3 weeks before closing
Title issues Liens, judgments, ownership chain problems Order title early in processing — don't wait for UW
Condo project not approved LO didn't check project approval before taking app For every condo, check Fannie/Freddie/FHA project approval list before writing a pre-approval
HOA litigation Condo HOA in active litigation Ask the question in pre-qual for every condo purchase

Phase 4: Underwriting#

4.1 Submitting to Underwriting — Checklist#

The processor is responsible for submission, but the LO should review this before signing off.

UW submission checklist:

  • Signed 1003 (all pages, all borrowers)
  • Credit report (tri-merge, within 120 days)
  • Full income package (tax returns, W-2s, pay stubs — all years, all pages)
  • Full asset documentation (all accounts, all pages)
  • Purchase agreement (purchase transactions — all addenda)
  • Appraisal (if ordered; or PIW confirmation if waiver obtained)
  • Title commitment (preliminary)
  • HOI (homeowner's insurance binder)
  • Flood determination
  • Disclosures — LE acknowledged
  • Arive file status updated to "Submitted to UW"
  • Notes entry documenting submission date, lender name, and loan number (assigned by lender)

4.2 Reading a Conditional Approval — What Each Condition Means#

Approval statuses from underwriters:

Status What It Means Next Step
Approved with Conditions (AWC) Loan is approvable — resolve the listed conditions Work conditions list
Suspended Underwriter needs more information before deciding Contact UW through lender's AE; gather requested info
Denied Loan does not meet guidelines Issue adverse action notice within 30 days (see Compliance)
Approved (Unconditional) Extremely rare before closing Verify all disclosures are complete; proceed to closing

Condition categories:

  • Prior to Docs (PTD): Must be resolved before closing documents can be ordered. These are hard stops.
  • Prior to Funding (PTF): Must be resolved and in the lender's hands before the loan funds. These are soft stops — closing can happen, funding cannot.
  • Informational: No action required; noted for the file.

Always read the full conditions letter, not just the summary. Underwriters sometimes bury important notes in condition descriptions.


4.3 Responding to Conditions — LO vs. Processor Responsibility#

See condition table in Section 3.2. The key principle: the LO is the client-facing role. Anything that requires the borrower's signature, statement, or action routes through the LO.

LO-written Letters of Explanation (LOE):

  • The LO drafts the LOE for the borrower to review and sign.
  • The LOE must be factual, specific, and first-person (borrower voice).
  • Do not write vague explanations. "I had a medical emergency in 2023 that resulted in the missed payments on my Chase credit card from March-May 2023. I have since paid the account current and have made all payments on time for the 18 months since." — specific, documentable, credible.
  • The borrower signs the LOE. The LO does not sign it on the borrower's behalf.

4.4 Suspense vs. Denial — What to Do#

Suspense: A suspended file means the underwriter couldn't make a decision with the information provided. This is not a denial. Reach out to the lender's Account Executive (AE) immediately.

  • Get the specific reason for suspension in writing
  • Determine whether it's a documentation gap or a guideline question
  • Assemble a complete response package
  • Re-submit through the lender's portal (tracked in Arive)
  • Log every conversation with the AE in Arive notes

Denial: A denial triggers immediate compliance obligations.

  • ECOA adverse action notice must be issued within 30 calendar days of a completed application (see Compliance Guide, Section 2 for details)
  • Document the denial reason in Arive
  • If the denial is based on credit report information, provide the credit bureau contact information to the borrower
  • Have a compassionate conversation with the borrower — explain what happened, what they can do to improve their position, and whether this is a "not yet" or a "no"
  • If you believe the denial was incorrect based on guidelines, contact the AE for a second review before accepting it

Phase 5: Closing and Funding#

5.1 Clear to Close Checklist#

"Clear to Close" (CTC) means underwriting has signed off on all conditions and the loan is approved to fund. This is not the same as funded. There are still steps.

CTC verification checklist:

  • Written CTC confirmation from lender (upload to Closing folder)
  • All PTD and PTF conditions confirmed cleared
  • Final loan terms confirmed (rate, payment, loan amount — match the LE)
  • If any loan terms changed from LE, verify whether a re-disclosure is required (see Compliance Guide)
  • Title company/escrow has been notified of CTC
  • Closing date and time confirmed with title/escrow and borrower
  • Closing Disclosure (CD) delivery timing verified (see Section 5.3)
  • Arive status updated to "Clear to Close"
  • Borrower notified — see CTC email template in Templates section

5.2 Coordinating with Title/Escrow#

In Oregon, the closing agent is typically an escrow company or title company. The LO's role is to facilitate communication, not manage the closing directly.

LO responsibilities with title/escrow:

  1. Provide escrow with lender contact information and loan number
  2. Confirm the closing date and time as soon as CTC is achieved
  3. Ensure escrow has the correct payoff amount (if refinance)
  4. Confirm wire instructions with borrower — verbal only first, then verify via known good phone number (wire fraud is rampant; never send wiring instructions via email without verification call)
  5. Confirm the borrower knows what to bring to closing: photo ID, funds to close (cashier's check or wire — specify which)
  6. Coordinate the final walkthrough reminder (purchase transactions)

Wire fraud advisory to borrowers: Issue this at every closing. Use the script in Templates & Scripts. This is not optional — wire fraud in real estate closings is a documented and growing threat. Log that you provided this advisory in Arive notes.


5.3 Final Disclosures — The Closing Disclosure and the 3 Business Day Rule#

The Closing Disclosure (CD) is issued by the wholesale lender — not CMS. The LO's responsibility is to ensure the lender issues the CD on time, confirm the borrower has received it, and monitor the 3-business-day waiting period before closing. Do not proceed to closing until you have confirmed receipt.

The CD must be received by the borrower at least 3 business days before consummation (closing day).

Business day definition for CD: This is stricter than the LE definition. For the CD, "business day" means all calendar days except Sundays and federal public holidays. Saturdays count.

Example: Closing is scheduled for Friday, March 14.

  • Saturday March 8: Business day ✓
  • Sunday March 9: NOT a business day ✗
  • Monday March 10: Business day ✓
  • Tuesday March 11: Business day ✓
  • Wednesday March 12: Final day CD must be RECEIVED by borrower

Working backward from Friday March 14: The 3 business day waiting period covers Tuesday/Wednesday/Thursday. The CD must be received (not sent) by Wednesday March 12 at the latest.

Delivery method matters:

  • Electronic delivery via lender portal (with borrower acknowledgment tracking): Deemed received same day if borrower clicks to acknowledge, or 3 days after delivery if no acknowledgment received
  • Email: Follow same electronic delivery rules
  • Hand-delivery: Deemed received day of delivery
  • Mail: Add 3 additional days for assumed delivery

Best practice: Push the lender to issue the CD as early as possible — do not let it go until the last legal day. Issues happen. If a correction is needed after CD issuance (certain changes trigger a new 3-day wait), you need time to fix it. Contact the lender AE proactively to ensure CD is issued with buffer.

Log CD receipt confirmation in Arive — note the date and method the lender delivered the CD, and the date borrower acknowledged receipt.

What triggers a new 3-day CD waiting period:

  1. APR increases by more than 1/8th of a percentage point (fixed rate) or 1/4th percentage point (adjustable rate)
  2. Loan product changes (e.g., fixed to adjustable)
  3. Prepayment penalty added

Changes that do NOT require a new waiting period:

  • Decrease in APR
  • Reduction in closing costs
  • Per diem interest adjustments for minor date changes

5.4 Funding Day — What the LO Does#

Funding is when the lender wires money to escrow. For the LO, this is mostly coordination and communication.

Funding day LO tasks:

  1. Confirm with title that the closing happened (borrower signed)
  2. Confirm with lender that funding has been authorized (most lenders fund same day as signing for purchases; refinances are typically 3 business days after closing — right of rescission period for non-purchase transactions)
  3. Notify borrower that funds have been disbursed
  4. For purchases: Confirm keys have been released (typically happens when escrow receives funding confirmation)
  5. Log funding date in Arive
  6. Update Arive file status to "Funded"

Refinance right of rescission: On any refinance of a primary residence, the borrower has 3 business days to rescind after signing. Funding cannot happen until this period has expired. If a borrower wants to rescind, they must do so in writing within the rescission period. Contact the lender immediately if rescission notice is received.


5.5 Post-Closing Follow-Up#

The closing is not the end of the relationship — it's the best opportunity to generate referrals.

24-48 hours post-closing:

  • Send personal thank-you email (see template)
  • Confirm borrower received all closing documents
  • Answer any questions about first payment date, escrow setup, etc.

30 days post-closing:

  • Check in: How's everything going? Any questions?
  • This is the natural moment to ask for a referral or review

Annual check-in system:

  • Set a 12-month reminder in your CRM at time of closing
  • Annual market update call/email — even if they don't need a new loan, you're staying top of mind for referrals

Oregon requirement: Keep borrower file records for a minimum of 3 years from the date of the loan transaction under OMLA. Federal records retention requirements may require longer — follow the most stringent applicable requirement.


Quick Reference: Transaction Timeline#

Phase Typical Duration Key Deadline
Pre-Qual to Application 1-7 days
Application to LE Immediate LE within 3 business days of complete application
Application to Processing submission 3-7 days All docs collected
Processing to UW submission 5-10 days
UW decision (initial) 3-5 days (lender-dependent)
Condition clearing 5-15 days
CTC to CD 1-2 days CD received by borrower 3 business days before closing
Signing to Funding Same day (purchase) or 3 business days (refi) Right of rescission for refi primary residence
Total typical purchase 30-45 days Per purchase agreement contingency dates
Total typical refinance 25-35 days

These SOPs represent current best practices at Capital Mortgage Source. Lender guidelines, investor overlays, and market conditions evolve — when a specific situation deviates from this guidance, contact your Operations Manager before proceeding.