Just a little reminder, ladies and gents, that DST ends at 2 a.m. local time on Sunday, November 6, if it is observed where you are.

"So what?" you might ask.

It affects the time zone portion of the disclosure you put on TRID loan estimates under Regulation Z § 1026.37(a)(13) for the expiration dates and times of any rate lock and for the "other estimated closing costs." If a date in that disclosure is on or after November 6, make sure you show the time zone with the "S" for standard time.

Thanks for the reminder - do you have the citation handy for that?

§ 1026.37(a)(13) (i) and (ii), and comment 37(a)(13)-3. The comment, by the way, uses an example of EST for Eastern Standard Time, which means that using "ET" for "Eastern Time" isn't sufficient. And that's because there are parts of each of the time zones in which DST isn't observed, so one must specify whether you are referring to standard or daylight time.

What would we do without you John. Putting it on my calendar to remind the MLO's.

The part of John's advice that initially got past me is you want to change it now because you're most likely locking rates that will expire under standard time.
So you could be preparing an LE today where the ten days out date is CDT but the lock expiration is CST.

Yes, Truffle, exactly. We have 45 day locks and longer even. I already tested and few and they still have EDT after Nov. 6, 2016. Systemic violations - woohoo!

Now, if your LOS were intelligently programmed, it would know whether DST is observed at the place where you want the deadline to be enforced, and whether the date input into the LOS is before or after the time change. And if pigs could fly ....

My pet pigs fly up the stairs for food... does that count??

Only if they are part of your bank's LOS.

Supposedly our system can't support two different time conventions (EST & EDT). You have to pick one or the other, which will then show up on both lines.

Thank you for the reminder John!

And what do you do if, for example, you lock the rate with the consumer the day you issue the loan estimate (for example, today, October 17) for 30 days, through November 16, which is after the time falls back, but the costs on the LE are only good for 10 business days, before the time change? Do you push out the second date to also fall after November 6?

Exactly, that is the issue. I can't believe our LOS does not support the ability to do two different labels for each section. Sounds like we'll just keep doing business as is and accept the systemic technical violations.