We are not open on Saturdays for full business functions. In a webinar it said that initial TIL delivery is based on the general rule (days you are open for business). I am now wondering if they were referring to placing disclosures in the mail (within 3 days of application) or the allowance of 3 days for receipt of the disclosures. It makes a difference in calculating when fees can be imposed because that is based on receipt of disclosures. I am 99% sure the general rule of delivering the disclosures is referring to when the disclosures would need to be in the mail but would love for someone to validate that for me. Thank you.

We are also not open on Saturdays. You are correct, use the General Definition for when you are required to provide E-TIL after receipt of an application (Per RESPA). The general rule applies to providing disclosures after receipt of an app, the precise rule applies to all timing requirements, 7/3/3.


From Reg. Z Section 216.19(a)(1)(ii)
If the disclosures are mailed to the consumer, the consumer is considered to have received them three business days after they are mailed.

Just an added note. Fees cannot be charged until the day after the 3rd business day.....similar to the ROR rule. So if the TIL is provided or mailed on Monday, fees cannot be assessed until Friday. This is how it was presented at the Triage Conference.