Having a bit of a debate on the definition of "Disbursement Date". We are in what's known as a "Dry Funding" state. When we close the loan, the funds are not given to the borrower directly same day. We order a wire and disburse funds to Escrow after loan docs are signed and returned to us. Escrow then disburses accordingly. For our CDs, which date would be considered the disbursement date. The date we send the funds to Escrow OR the date Escrow actually disburses them to the borrower/seller/third parties?

(iii) Disbursement date. The date the amount disclosed under paragraph (j)(3)(iii) (cash to close from or to borrower) or (k)(3)(iii) (cash from or to seller) of this section is expected to be paid in a purchase transaction under § 1026.37(a)(9)(i) to the consumer or seller, respectively, as applicable, except as provided in comment 38(a)(3)(iii)-1, or the date some or all of the loan amount disclosed under paragraph (b) of this section is expected to be paid to the consumer or a third party other than a settlement agent in a transaction that is not a purchase transaction under § 1026.37(a)(9)(i), labeled “Disbursement Date.”

Given the Regulation's "definition" of the disbursement date, I'm thinking it would be safe to say we should be using the date Escrow distributes the money.

I would concur