My interpretation of that rule is that it need not be available months in advance or months after, as examples. There may be a planned loan for, say June 15, because that is when the item will be delivered and paid for. So the disclosures might be available from June 7-15.
Last edited by Andy Z; 05/19/17 08:06 PM.
Using the banks hours may require the borrower in Germany to get up in the middle of the night to call your number because that is when you're open. I don't see that as reasonable or expected. And they may need a window of time to make this call based on their mission and availability. That said, I believe the intent of the toll free is cost and with a recording being available, less of a structured time requirement, but that is not stated.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell