Under the new rule, the business days for delivery of the Loan Estimate is defined as "For purposes of § 1026.19(e)(1)(iii)(A), the term “business day” means a day on which the creditor's offices are open to the public for carrying out substantially all of its business functions."

In other words if you are not open for substantially all of your business functions, you may exclude Saturdays.

Washington Law requires a rate lock disclosure to be disclosed within 3 business days, including Saturdays (WAC 208-620-510).

In our LOS, the disclosure is included in the 3 day application package, however the system is excluding Saturdays because we are not open when doing the calculation for the Loan Estimate Delivery.

Would it be accurate to say that if the WA disclosure is sent at the same time as the Loan Estimate, by excluding Saturdays under TRID, we would be violating state law regarding delivery of the WA disclosure?

Looks like your legislature has a little work to do to re-sync State law with Federal law, but to answer your question, I would say yes you would be in violation of State law. I didn't research what the penalties are for disclosing late. If there really is no civil liability, you might want to check with your State department of banking to see how they plan on enforcing this until it can be amended. You are going to have a hard time putting the rate lock fee in Block 2 on the GFE and on Line 802 of the HUD also.

Of course this should not be a new issue for you with TRID? The GFE delivery time is defined in the same way.

Thank you, rlcarey, I appreciate it!