Just when you think things are running smoothly, your loan review guy comes and asks you a question that makes your brain hurt.

Scenario: We are not open on Saturdays at any of our branches.
1.) Do Saturdays count for the purpose of providing the ETIL?
2.) Do Saturdays count for the purpose of the 7 Day TIL waiting period?
3.) Do Saturdays count toward the ROR days?

Any other thoughts?

(6) Business day means a day on which the creditor's offices are open to the public for carrying on substantially all of its business functions. However, for purposes of rescission under §§1026.15 and 1026.23, and for purposes of §§1026.19(a)(1)(ii), 1026.19(a)(2), 1026.31, and 1026.46(d)(4), the term means all calendar days except Sundays and the legal public holidays specified in 5 U.S.C. 6103(a), such as New Year's Day, the Birthday of Martin Luther King, Jr., Washington's Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day.

So.....


Scenario: We are not open on Saturdays at any of our branches.
1.) Do Saturdays count for the purpose of providing the ETIL? NO
2.) Do Saturdays count for the purpose of the 7 Day TIL waiting period? YES
3.) Do Saturdays count toward the ROR days? YES