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#2118427 - 02/15/17 07:51 PM Dates on Closing Disclosure
Baker Offline
Platinum Poster

Registered: 11/23/05
Posts: 738
Loc: Washington State
On the Closing Disclosure you have to include the date issued, closing date and disbursement date.

If you are providing the disclosures electronically (in compliance with e-sign) don't we still have to follow the 3 + 3 day rule in calculating the dates?

For example:
Date issued 12/15/16; Closing Date 12/22/16 (3 days to receipt, 3 days waiting); Disbursement Date 12/27/16 (this would have included Christmas observed).

OR can you assume that they will open it within 3 business days and disclose the dates like you would for in person?

For example:
Date issued 12/15/16; Disbursement Date 12/19/16; Disbursement Date 12/23/2016

I know that you can start the waiting period if you receive confirmation... I am just not sure how to disclose the dates, do you or do you not base it on the assumption they will open?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2118433 - 02/16/17 07:27 AM Re: Dates on Closing Disclosure [Re: Baker]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 64016
Loc: Galveston, TX
You could do it based on the assumption that they do not open it and then if they opened it early and want to close sooner, you would issue a revised CD at closing with the updated dates. However, if you already have a set closing date and are in contact with the customer and they know they have to open and review the CD by a specific deadline, you could go the other way. I see no harm going in either direction based on the best information known at the time of issue.
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