A few of our staff attended a seminar and the instructor said that as long as one of the consumers on the transaction received the CD, for example in person, then loan loan could close in three days even if the other consumer's CD is being received by mail and they are considered to have received the CD three days after mailing it (assuming no rescission).
Is this because of the multiple consumers rule at 1026.17(d)? - In transactions that are not rescindable, the disclosures required by § 1026.19(f) may be provided to any consumer with primary liability on the obligation.
So even if we provide a CD to everyone on the loan, as long as we have proof of receipt for at least one of the borrowers that are primarily liable (which all of them would be individually responsible since they are co-borrowers), we can close the loan and not wait for receipt for the other borrowers...
Please confirm. Thanks in advance.
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