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#2011154 - 04/29/15 09:56 PM Closing Disclosure: Date Delivered
Norman Paperman Offline
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Norman Paperman
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Am I crazy again or did these donkeys mess up their own sample?

If the closing disclosure is required to be delivered to the customer at least three business days prior to consummation, why does this sample have the date of closing listed for the date issued?

http://files.consumerfinance.gov/f/201403_cfpb_closing-disclosure_cover-H25B.pdf
Last edited by Norman Paperman; 04/29/15 09:57 PM.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2011167 - 04/30/15 02:37 AM Re: Closing Disclosure: Date Delivered Norman Paperman
rlcarey Offline
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Because there is no context as to what this disclosure represents. It could be a revised disclosure issued at consummation.
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#2011201 - 04/30/15 01:47 PM Re: Closing Disclosure: Date Delivered Norman Paperman
Jerod Moyer Offline
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The CFPB indicated to us that the example demonstrates what a revised CloD could look like since it COULD be provided at or before closing. Therefore the date issued, closing and disbursement COULD all match. The initial CloD would NEVER look that way.
Last edited by Jerod Moyer; 04/30/15 01:48 PM.
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#2011340 - 04/30/15 05:48 PM Re: Closing Disclosure: Date Delivered Norman Paperman
John Burnett Offline
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If they had said that in their description of the sample, it would have denied us all an opportunity to scratch our heads and question the Bureau's accuracy. You cannot imagine how many people have pointed out that date. Yesterday, I suggested the drafter of the form was having anxiety over his tax filing (4/15/13?)

While we are on the topic of dates, has everyone else out there noticed there is no guidance anywhere for how the date is to be formatted? My first thought was to say you use the samples as exemplars for how to do it. That got shot down when someone pointed out there are samples using the 4/1/15 format and the 4/1/2015 format.
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#2011352 - 04/30/15 06:04 PM Re: Closing Disclosure: Date Delivered Norman Paperman
RR Joker Offline
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I think I'm going to let my software vendor figure that one out. wink
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#2011436 - 04/30/15 08:38 PM Re: Closing Disclosure: Date Delivered Norman Paperman
Norman Paperman Offline
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And now you understand why my avatar is Corp. Klinger. I'm getting closer to earning my Section 8 every day.
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#2011698 - 05/01/15 08:16 PM Re: Closing Disclosure: Date Delivered Norman Paperman
John Burnett Offline
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And a fine likeness it is, Norman! One of my favorite entertainments of all time. It didn't matter whether a given episode was hilarious or poignant, it was a terrific show with fantastic writers.

And CPL Klinger was ever outrageous!
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