Skip to content
BOL Conferences
Thread Options
#2102474 - 10/10/16 07:15 PM Date of issue not a business day
Vive Accommodare Offline
Platinum Poster
Vive Accommodare
Joined: Apr 2013
Posts: 581
Compliance
If the loan estimate or Closing Disclosure are issued on days that are not defined as business day, i.e. Sunday or Federal Holidays, is there a violation? I understand for timing purposes, the tracking aspect would start the next business day, but I want to make sure there isn't a violation by issuing disclosures on non-business days.
_________________________
"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill

Return to Top
TRID - TILA/RESPA Integrated Disclosures Rule
#2102476 - 10/10/16 07:30 PM Re: Date of issue not a business day Vive Accommodare
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,374
Galveston, TX
There is no violation, just that the clock does not start as you indicated until the next business day.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2102478 - 10/10/16 07:47 PM Re: Date of issue not a business day Vive Accommodare
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
I was having a conversation on another forum about a similar topic. One thing to throw it is that for LE purposes related to meeting the 3-day timing rule for initial or revised Loan Estimates, you could use today for those rules if it is a day that your company is open to perform substantially all of its business functions. But, for timing issues related to closing, such as the 7 day rule for the LE and the 3 day rule for the CD, you would not be able to count today.

Return to Top
#2102479 - 10/10/16 07:52 PM Re: Date of issue not a business day Vive Accommodare
Vive Accommodare Offline
Platinum Poster
Vive Accommodare
Joined: Apr 2013
Posts: 581
Compliance
We are always open for Columbus Day, just not any other Federal Holiday. We cannot perform all functions though, we are limited due to Title Companies and Banks being closed today.
_________________________
"Tact is telling someone to go to [censored] in such a way, they look forward to the trip" Winston Churchill

Return to Top
#2102482 - 10/10/16 08:27 PM Re: Date of issue not a business day Vive Accommodare
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
It would depend on what was trying to be done. We are open too and we needed a closing to take place. We found a settlement company that was open.

Return to Top