Answer:
226.15 and 226.23 define what would be required in the rescission. And since all "material disclosures" have not been delivered (the RoR) the clock has gone to 3 years or 3 days from when you make all the required "material disclosures".
The decision now is whether you let a sleeping dog lay, or provide the RoR and decrease your customer's time to rescind.
First published on BankersOnline.com 6/3/02