Reg Z - Timing of Corrected Early Disclosures

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Question:

If you give the customer corrected early disclosures, and you mail them, do you have to wait six days before getting the final documents signed? Do you have to assume it took three days for them to receive and wait another three days? If it is their primary residence, do you still have to wait another three business days before funding? Does the seven days and the three day waiting period on the early disclosures apply to rental properties as collateral, if the purposes of the funds is consumer, such as child education, buying a car, etc.?

Answer:

If you have to redisclose and you mail the disclosures, you have to allow three precise business days for them to receive the disclosure, and another three precise business days before you close the loan, and if it's their primary residence, another three precise business days for the right of rescission to expire before you can disburse the funds. If the loan is for a consumer purpose and secured by a dwelling that the consumer owns, then the Reg Z disclosure timing requirements will apply.

First published on BankersOnline.com 10/26/09