Not necessarily. You count from the rollover date, which was 12/7, so the closeout date fell after the mandatory regulatory penalty period (which would have been waived because it's in the grace period). So the closeout came when the bank had the legal and regulatory option to waive any penalty.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8