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Compliance Question of the Week

Question: Why is Saturday a business day automatically in some aspects of Regulation Z and not in others?

ANSWER:

Saturday is automatically considered a business day for purposes of the Right of Rescission delay period, the three days from receipt timing for closing and the Closing Disclosure, and the requirement to delay any closing subject to TRID until at least the seventh business day from receipt of application and delivery of disclosures.

The only instance where lenders have to determine whether they are substantially open is for purposes of determining if they have to count Saturday to meet the requirement to deliver an LE within three days of receipt of an application. If you do not meet this standard, Saturday is automatically disregarded, effectively giving the lender one more day to disclose.

Reference: 12 CFR 1026.2(a)(6), 1026.19(a)(2), 1026.19(b), 1026.19(e)(1)(iii), 1026.19(f)(ii).

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