Someone....please enlighten me!

Regarding "Section 32" loans, Kirchman (BOB) states that the required disclosures must be given "at least three business days before consummation."

I cannot find any reference to this in the Reg. I've read the Fed's and FDIC's versions 'til, I'm blue in the face, and cannot find any reference to the timing of the required disclosures.

Where in the world is it written.....or is BOB incorrect?

Thanx....

The timing requirement is in 226.31(c), titled "Timing of disclosure." It's a case of the timing rule before the content requirement. That's probably why it was invisible when you looked.

In detemirmining the "waiting period", it is also important to look at the commentary for the citation. It states that the waiting period is three business days, just like the recision period on refis. However, the third day for refis expires at midnight at the end of the third business day while the third day for the waiting period for section 32 loans ends anytime during the third business day (effectively resulting in one less day when compared to the recision period).

The devil is in the details on this one.

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Robert Marx
Opinions stated are not necessarily that of my employer.

Thanx, people.

It never occurred to me that the rules for timing of the disclosure would be located in a different section from the rules.

On the other hand, if I had had my thinking cap on, I would have realized that looking elsewhere would be the "logical" place to look. In other words, where the regs are concerned, "logical" means "illogical."