During a recent independent audit, we were cited as non-compliant with the GFE Important Dates section #2 for the bank not properly calculating 10 business days during October because we added Columbus Day as a business day. The bank was open for business on Columbus Day, however they are claiming non-compliance based on Reg. Z. Is this accurate? When I look to the definition under RESPA I don't agree.

Reg Z definitions and RESPA def's are not the same. Even Reg Z only counts Federal Holidays for certain sections of the reg, such as ROR.

Reg Z excludes Sundays and Federal Holidays as business days from the ROR even if the FI is open. See 226.2(a)(6) and its Commentary.

I understand the Reg. Z issues under 226.(2)(a)(6), my point is this shouldn't apply to the definition of business days for the GFE Important Dates section, right?

As I read the quote above it is saying Reg Z includes (counts) Federal Holidays for the ROR when it doesn't.

I just wanted to clarify that Reg Z excludes them from the ROR so someone would not take away any misinformation.

RESPA does not exclude Sundays and Federal Holidays in its definition of a business day with the exception found in 3500.7 for the timing of when a GFE is received when mailed in place of providing it face to face.

Maybe I worded my comment poorly...but it says Regulation Z only considers Federal holidays for certain sections of the reg...(ROR, for example) Other sections would count them only if you are closed.