Are we expected to extend the closing of a HELOC (1st lien on dwelling) if the closing will not be three days out from application date. Example: Application Date is 5/1/18. Customer signed Optional Waiver of Timing Requirement on 5/1/18. Documentation of Delivery of Appraisal 5/2/18. Loan Closed on 5/3/18. From my interpretation of the reg we are in violation because we did not allow the customer three days to review the appraisal prior to consummation, or three days before closing to consider the waiving of the timing requirement?

Correct - they have to waive at least three days prior to closing.