New Reg Z Requirements - Disclosure Dilemma

My understanding is that the two points in time where the mailing delay period comes into play are with re-disclosure due to initial early disclosure becoming inaccurate prior to closing and with regard to collecting a fee (other than credit report fee). Jack is correct. The initial early disclosure requirement is satisfied if it is mailed or delivered within three business days of receipt of the application, no additional three business days for presumed delivery here, but if you mailed these initial disclosure you can't collect a fee until you wait three business days for delivery. Finally, if the APR on your initial disclosure becomes inaccurate, you have to re-disclose and wait an additional three business days from date of delivery to close. If you mailed that re-disclosure, it is not considered delivered until three business days after mailing, so in essence, it would be six business days from the date of mailing.

First published on BankersOnline.com 10/19/09