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#2170736 - 03/28/18 09:52 PM TRID 101 - Timing
swiggles Offline
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Review

For LE delivery, we count Saturdays, but not Sundays or Legal Holidays
For CD delivery, we count all business days in which the bank is open for substantially all of its business functions, so we don't count Saturdays, Sundays and Legal Holidays.

I was reviewing Timing under the definitions and it made my head spin in circles. It has been a long time since I have looked at this. I must have lost some brain power.

(6) Business day means a day on which the creditor's offices are open to the public for carrying on substantially all of its business functions. However, for purposes of rescission under §§ 1026.15 and 1026.23, and for purposes of §§1026.19(a)(1)(ii), 1026.19(a)(2), 1026.19(e)(1)(iii)(B), 1026.19(e)(1)(iv), 1026.19(e)(2)(i)(A), 1026.19(e)(4)(ii), 1026.19(f)(1)(ii), 1026.19(f)(1)(iii), 1026.20(e)(5), 1026.31, and 1026.46(d)(4), the term means all calendar days except Sundays and the legal public holidays specified in 5 U.S.C. 6103(a), such as New Year's Day, the Birthday of Martin Luther King, Jr., Washington's Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2170741 - 03/28/18 10:14 PM Re: TRID 101 - Timing swiggles
rlcarey Offline
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Galveston, TX
It depends on what delivery you are talking about. When you have to get them or when they are considered delivered?

The three business days to get a LE out depends on when you are open. If you mail them, they get them in three business days regardless of being open.

The three business days before closing for a CD - it again does not matter if you are open or not.

So, we really need to know specifically to what you might be referring.
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#2170811 - 03/29/18 01:45 PM Re: TRID 101 - Timing swiggles
swiggles Offline
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OK. We are not open on Saturdays.

We have always counted Saturdays for LE timing.

For CD timing, we do not.

I thought this might be the difference between a "precise" business day and a "general" business day (just names given to counting methods).
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#2170816 - 03/29/18 02:06 PM Re: TRID 101 - Timing swiggles
rlcarey Offline
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It is. "Precise" refers to those that are specifically defined in the regulation in the section that you quoted (Sundays and Legal Federal Holidays excluded). The secret is to parse the actual application. i.e., §§ 1026.15 and 1026.23, and for purposes of §§1026.19(a)(1)(ii), 1026.19(a)(2), 1026.19(e)(1)(iii)(B), 1026.19(e)(1)(iv), 1026.19(e)(2)(i)(A), 1026.19(e)(4)(ii), 1026.19(f)(1)(ii), 1026.19(f)(1)(iii), 1026.20(e)(5), 1026.31, and 1026.46(d)(4),

I did this one time in threads as to exactly what these sections refer too - not sure if I can find it again.
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#2170821 - 03/29/18 02:16 PM Re: TRID 101 - Timing swiggles
swiggles Offline
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I found the cfpb's "Integrated Disclosures Timeline example.

"For purposes of providing the Loan Estimate.....a business day is a say on which the creditor's offices are open to the public for carrying out substantially all of its business functions.

"For all other purposes, business day means all calendar days except Sundays and legal public holidays......"
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#2170823 - 03/29/18 02:19 PM Re: TRID 101 - Timing swiggles
swiggles Offline
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Quote:
I did this one time in threads as to exactly what these sections refer too - not sure if I can find it again.


....would love to have it...if you happen to find it. I did look each one up but didn't keep a record of my findings.

Hey...I attended a seminar yesterday, where Shannon Phillips was the speaker. He mentioned you by name. Were your ears burning? wink
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#2170825 - 03/29/18 02:23 PM Re: TRID 101 - Timing swiggles
RR Joker Offline
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The Swamp
The calculator somewhere in tools does a very good job of this. wink
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#2170833 - 03/29/18 02:31 PM Re: TRID 101 - Timing swiggles
rlcarey Offline
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Swiggles - I wondered what was going on yesterday - I thought my A/C was on the fritz.

Here it is:


Precise Business Days
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#2170839 - 03/29/18 02:47 PM Re: TRID 101 - Timing rlcarey
swiggles Offline
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laugh
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#2170847 - 03/29/18 03:09 PM Re: TRID 101 - Timing swiggles
swiggles Offline
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If it helps anyone, I created this in a Word document for my own retention, using Randy's post in the linked thread. Hopefully, I will never get confused again.

REGULATION Z – BUSINESS DAY

1026.2 -- Definitions
(6) Business day means a day on which the creditor's offices are open to the public for carrying on substantially all of its business functions. However, for purposes of rescission under §§ 1026.15 and 1026.23, and for purposes of §§1026.19(a)(1)(ii), 1026.19(a)(2), 1026.19(e)(1)(iii)(B), 1026.19(e)(1)(iv), 1026.19(e)(2)(i)(A), 1026.19(e)(4)(ii), 1026.19(f)(1)(ii), 1026.19(f)(1)(iii), 1026.20(e)(5), 1026.31, and 1026.46(d)(4), the term means all calendar days except Sundays and the legal public holidays specified in 5 U.S.C. 6103(a), such as New Year's Day, the Birthday of Martin Luther King, Jr., Washington's Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day.

Precise Business Day (count Saturday but do not count Sunday or Legal Holidays)
1026.15 – Right of rescission period for open end credit
1026.23 – Right of rescission period for closed end credit
1026.19(a)(1)(ii), - Timing of imposition of fees on a reverse mortgage
1026.19(a)(2), - reverse mortgage – seven day receipt waiting period
1026.19(e)(1)(iii)(B), - Loan Estimate – seven day receipt waiting period
1026.19(e)(1)(iv), - Loan Estimate – three day receipt period for mailing
1026.19(e)(2)(i)(A), - Timing of imposition of fees after Loan Estimate receipt
1026.19(e)(4)(ii), - Relationship between issuing an Loan Estimate and Closing Disclosure
1026.19(f)(1)(ii), - Closing Disclosure – three day receipt period for closing
1026.19(f)(1)(iii), - Closing Disclosure – three day receipt period for mailing
1026.20(e)(5), - Escrow Account Cancellation Notice
1026.31(c) – High Cost Mortgage disclosures
1026.46(d)(4) – Private Education Loan disclosures

If it is not on the above list, business day defaults to any day on which the creditor's offices are open to the public for carrying on substantially all of its business functions (General Business Day).

So, for example, the bank has three general business days to provide or mail the loan estimate. The applicant then has ten general business days to provide the intent to proceed. Any other timing requirements that are not on the above list, such as the billing error dispute are also calculated using the general business day definition.
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#2170856 - 03/29/18 03:43 PM Re: TRID 101 - Timing swiggles
swiggles Offline
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Quote:
The calculator somewhere in tools does a very good job of this. wink


Found the calculator Joker. Thanks!
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#2170998 - 03/29/18 09:50 PM Re: TRID 101 - Timing swiggles
Compliance NABW Offline
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A relatively easy way to remember is anything to do with the CD and anything to do with days before consummation require the "Specific" Business Day definition. While, those things that deal with issuance of the LE (initial and revised) use the "General" Business day definition. And, the "mailbox rule" uses the "Specific" Business Day definition.

So, for CD timing, you can/should count Saturday as a Business Day.

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