May 2, 2013 CFPB "Equal Credit Opportunity Act (ECOA) Valuations Rule" guide states on Page 13:

"When processing an application for a closed-end loan, you must deliver copies of appraisals or other written valuations "promptly upon completion", or three business days before consummation, whichever is earlier. For example, if a loan will close on Friday, April 4, you must deliver the valuation no later than Tuesday, April 1."

So the day you deliver it is considered Day 1, correct?

I had been thinking that you delivered it, waited three business days and then closed the loan. Guess I was wrong. Go figure!

You can count in either direction, using the starting point as Day Zero.

If Tuesday is the delivery date, counting forward, Wednesday is is the first BD after delivery and Friday is the third. You can close on the third BD after.

Using the words of the regulation, delivery has to be no later than the third BD before consummation, start with Friday as the day of consummation as Day Zero. Tuesday is the third BD before that day, so delivery must be no later than Tuesday.

Hi - can "Business Day" be clarified under ECOA? I need affirmation before I push back an LO's closing :-(
I think it is all days except Sundays and federal legal holidays.

Disregard...I found another thread that answers my question...Sorry!