Our rescission notice is formatted around the model form in the Reg. The question we have is whether we need to change the date of the transaction and the corresponding date that rescission ends when the customers do not sign on the date of the loan docs.
There IS a place for the customer to sign and date when they receive the required disclosures (actual date of signing). My thought is that since they sign this section, and the form clearly states that rescission ends AFTER the last of three things happen (receiving the disclosures being one of those things), then we wouldn't have to have the title companies revise the rescission date preprinted on the form.
Any one else have this issue?

It also requires the date the rescission period expires, which is usually calculated from the date the documents are supposed to be signed. If they sign them at another time the date would be incorrect. See below (v).

The notice shall be on a separate document that identifies the transaction and shall clearly and conspicuously disclose the following:
(i) The retention or acquisition of a security interest in the consumer's principal dwelling.
(ii) The consumer's right to rescind the transaction.
(iii) How to exercise the right to rescind, with a form for that purpose, designating the address of the creditor's place of business.
(iv) The effects of rescission, as described in paragraph (d) of this section.
(v) The date the rescission period expires.

Why would the customers be signing docs dated a different date?
Seems to me the simple solution is if they don't come in the day they're supposed to, you do a new closing package with the correct date on it.

The only exception I can see is if you were sending docs out to be signed by a borrower who wasn't able to be at the closing. But that would be a pre-sign.

It seems that we have LOTS of borrowers that don't get to signing on the date they are supposed to. Not sure why?? Since we would have to get new docs to the title company it just seems like lots of extra work and paper to re-do the docs if the borrower misses the date.
What do you mean by a pre-sign?

I would find out why. Sure beats all these loans being subject to rescission for three year and also as a defense in foreclosure.