We originated a refinance to a H&W that is getting rejected by our investor due to a TRID timing error on the CD. One of the borrowers was giving the initial CD 3 days prior to closing, and the other came in the next day. We started our 3 day waiting period when we gave the CD to the first borrower, but the investor is saying that because the loan is rescindable, the 3 days doesn't start until both receive the disclosure.

I know that everyone with the right of rescission is required to receive a copy of the CD before the rescission period begins, but does that same rule apply to the 3 day CD waiting period before closing?

In rescindable transactions, the disclosures required by § 1026.19(f) must be given separately to each consumer who has the right to rescind under § 1026.23.

Delivery of the CD is required at least three business days before closing under 1026.19(f)

That's the same conclusion I came to, but I was hoping I was wrong. Thanks Randy.