I see the point you raise. Reg. Z leaves "consummation" to be defined by state law. I didn't see anything in the RCWs, WACs, Consumer Loan Act, etc. defining consummation.
There's some information on the DFI's site regarding MDIA where they define consummation as when the loan documents are signed. So I'm going to opine that the borrowers are contractually obligated when they sign, but can unwind the transaction by exercising their right of rescission. Or at least that's how I understand it.....
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No, I didn't lose my mind. It got scared and ran away.