We have not been including Saturdays as a "business day" because not all of our business functions are opened to the public. However, the ECOA Appraisal Rule Small Entity Guide states we "can apply your own reasonable definition, which may include counting Saturdays - as provided in the alternative definition in Regulation Z".

Just want to confirm if we can count Saturdays as a business day for the appraisal requirements (providing the notice and the delivery of appraisal) even though we are not open to the public for carrying on substantially all of our business functions.

Thank You.

You can count Saturday for the ECOA Appraisal rule and that's nice because then the delivery of the appraisal and CD line up well. But be careful if you make HPML loans. A careful reading of the precise definition of business day in Reg Z which lets you count Saturday as a business day does not include 1026.35 (which is the HPML rules). So, if you count Saturday for the ECOA Appraisal Rule, you cannot apply the same definition of business day to the HPML Appraisal rule.

Thank You.