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#2255631 - 06/18/21 08:50 PM Re: Juneteenth rainman
Comply 101 Offline
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Our investors stated they would not take a loan from us with the incorrect disbursement date, even going back to the 15th closings. As Randy stated, we will have to issue revised RofR and CDs on some loans.
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TRID - TILA/RESPA Integrated Disclosures Rule
#2271599 - 06/13/22 10:24 PM Re: Juneteenth RebekahL CRCM
Vive Accommodare Offline
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Compliance
so to revive this for the holiday this year, if our Investors/Warehouse Lines are closed yet we are not, could we still count Monday (6/20) by the general definition?
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#2271601 - 06/13/22 10:40 PM Re: Juneteenth RebekahL CRCM
rlcarey Online
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Galveston, TX
Your investor has absolutely nothing to do with the business day definition if you are the creditor on the loan.
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#2271604 - 06/13/22 11:42 PM Re: Juneteenth RebekahL CRCM
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We had every intention of counting it as a business day, but the Investor has come back to say they aren't open so we can't count it for timing purposes. Needless to say this is going to be a long string of emails. Coffee anyone?
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#2271605 - 06/14/22 11:15 AM Re: Juneteenth RebekahL CRCM
rlcarey Online
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In who's name are you closing the loan? And they say you cannot count Monday as a business day for what purposes?
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#2271608 - 06/14/22 02:14 PM Re: Juneteenth RebekahL CRCM
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Compliance
We close all loans in our name, which is why we are counting it. We've asked the Scenario Desk at the Investors to escalate it to their Compliance department. The Scenario Desk is staying firm with Monday being "counted" as a holiday.
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#2271612 - 06/14/22 02:58 PM Re: Juneteenth RebekahL CRCM
rlcarey Online
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Well, you know what they say. He who has all the gold makes all the rules. So it goes with investors.
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#2271654 - 06/14/22 10:14 PM Re: Juneteenth RebekahL CRCM
Vive Accommodare Offline
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Compliance
unfortunately that's how it usually goes
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#2271670 - 06/15/22 02:35 PM Re: Juneteenth RebekahL CRCM
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Why wouldn't you treat this the same as you do any other holiday? I understand the scramble for last year when it was first declared but this year it's nothing new.

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#2271671 - 06/15/22 02:38 PM Re: Juneteenth RebekahL CRCM
rlcarey Online
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I am not sure TR, but if your investor has stated a position and you want to sell the loan to them, you have to follow their rules.
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#2271676 - 06/15/22 03:06 PM Re: Juneteenth RebekahL CRCM
Truffle Royale Offline

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I've not seen an investor who isn't following the same holiday schedule for all holidays in 2022. We just follow FNMA with the knowledge that most investors do too. KISS so the loan is saleable today or in the future.

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