We had a HELOC (1st lien position) where the docs were dated for 3/22/11; however, the lender had the customer sign the docs on 3/16/11. Therefore, the mortgage was notarized on 3/16/11 and the receipt of right to cancel was dated 3/16.

From a rescission stand-point, when is the first date in which we can disburse funds?

3/20/11 assuming a copy of the material disclosures were also provided.

However have fun explaining to an examiner you allowed a consumer to sign a legal document 6 days before its contractual date.