Reg Z Early Disclosures - Add 3 Days for ROR Loans

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Question:

If we can't close on a loan until seven business days (relative to the Reg Z Early Disclosure rules that were effective July 30, 2009) after the application and disclosure date (at the earliest), do we need to add an additional three days onto that for loans with rescission?

Answer:

Yes, the ROR can not run concurrently with the 7/3/3 business days required by the new MDIA rules. Assuming you provide the disclosures in person or place them in the mail today 8/4, and assuming no redisclosure is required, you could close the loan on Wednesday 8/12 and if rescission is applicable you would be able to disburse on Monday 8/17.

First published on BankersOnline.com 10/05/09