Technically, yes. Although then you might have an examiner asking about customer confusion and UDAAP in providing the consumer with multiple rights of rescission with various expiration dates, but that is the way I would have definitely gone.
Or technically, I believe that you could have provided it even later and given them three business days from the delivery of the right of rescission notice with a proper date three business days in advance, as long as it was prior to allowing any draws. Once the first draw was allowed - the goose was cooked.
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