Agree with Adam. If the term isn't specific or defined to mean business days, and this change in terms is not, it's calendar days.
Reg E pre-dates Reg DD which uses a 30-day change period. If making Reg E and Reg DD changes, you can break the two up, or use 30-days in place of 21 and give the consumer more time.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell