Customer applies for a 5/1 ARM. 3 days before closing the customer decides he wants a 10/1 ARM. The revised ETIL is provided in person. Does the 7 day waiting period apply?

I would say yes, because it is a new product and the customer would need the time to review the documents and decide if this loan is in their best interest.

If you provided it in person, MDIA says it's only three days that you have to wait. The additional 3 would be if you had mailing time. So you can close on the fourth day after providing the revised ETIL. Check out BOL Tools for a great MDIA calendar to download and use for free!

Thanks Truffle. I just wanted verification that the 7 day rule applied only to the 1st ETIL provided at application.

ahou, that's not right. It applies to every etil you issue. In the case you mentioned, the 7 days was cut to 3 (with closing on the 4th day) because you delivered in person. Had you mailed the disclosure it would have been 7 days.

If the revised ETIL is mailed you can close on the 6th business day after it's mailed.

Initial ETIL - you can close on the 7th business day whether provided face to face or mailed.

Revised ETIL - Face to Face you can close on the 3rd business day. Mailed - you can close on the 6th business day. HOWEVER, the 3 and 6 business day is dependent on the the original 7 business days having expired. If you issue a revised ETIL face to face on day 2 of the original 7 business days waiting peroid you would have to wait for the 7 days to expire before you could close.

There are 2 waiting periods - the 7 day rule and the 3 day rule. If you re-disclose you don't have to apply the 7 day rule again (the 7 days doesn't start over beginning with the revised TIL) we just have to apply the 3 day rule - that was my question.

There are 3 waiting periods - 7 day initial disclosure regardless of delivery method - 3 day face to face re-disclosure - 6 day mail re-disclosure.

If the initial 7 day waiting period has expired then re-disclosure does not trigger a second 7 day waiting period. Depending on the delivery method of the re-disclosure it will be 3 days or 6 days. However, to restate, the initial 7 day waiting period must have expired. IOWs you must always wait a minimum of 7 days from the initial disclosure. The exception would be a waiver in the presence of a bona fide financial emergency.

Thanks, that's what I thought.