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Closing Disclosure​ and Disbursement Date

Question: 
I have a question about​ a ​Closing Disclosure​ and the​ Disbursement Date on a no​ rescission loan with payoffs requiring funds from borrower received on the​ next day. Would we disclose the ​Disbursement ​Date on the CD as the same day​ as the closing date or the date we receive the borrower's funds and the​ actual funds are disbursed?
Answer: 

1026.38(a)(3)(iii) Disbursement date. The date the amounts disclosed pursuant to paragraphs (j)(3)(iii) and (k)(3)(iii) of this section are expected to be paid in a purchase transaction under § 1026.37(a)(9)(i) to the consumer and seller, respectively, as applicable, or the date the amounts disclosed pursuant to paragraphs (j)(2)(iii) or (t)(5)(vii)(B) of this section are expected to be paid to the consumer or a third party in a transaction that is not a purchase transaction under § 1026.37(a)(9)(i), labeled “Disbursement Date.”

First published on 02/05/2017

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