A recent seminar suggested that line 4 be 6 days due to the 3 day wait for the new GFE plus the 3 day assumption of delivery if mailed.

However, does this OBLIGATE us to wait the full 6 days? If nothing has changed and the borrower picks up the final GFE, can we close sooner than 6 days if we so choose? I can't find anything in the FAQ.

Thanks

What 3 day wait for a GFE and 3 day assumption for mailing? You can give them a new GFE 10 minutes before you close if you want to.

After you wait (if mailed) for the initial GFE to be received by the customer there are no more waiting periods in RESPA.

Reg Z is another story...

MDIA, where the 3+3 day waiting period comes in to play, is in regrad to a redisclosed TIL only.
You do not have to give a new TIL every time you give a new GFE.
The only time they must go out together is the first time.
After that, you can redisclose the GFE as many times as you have a valid changed circumstance.
The only time you need give another TIL is if the valid changed circumstance causes fee changes that move the APR by more than .125%.

Right, but my question is this...

Does the number in Line 4 OBLIGATE you to wait the stated number of days?

My feeling on it is that it's a way for us to not be pressured by the borrower. We tell them that they must finalize things with us at least 6 days before closing and if we choose to close sooner, that's our choice.

I'm not seeing anything in any commentary or FAQ that addresses this.

No, there's nothing in the Reg that says you MUST wait the number of days you put in line 4.
The use of six days was a SUGGESTION made, as near as I can tell, to allow you enough time to redisclose the TIL if the rate lock necessitated it. It had nothing to do with your feeling that it was to keep the borrower from bringing pressure to bear with regard to the closing date.

4) Q: If the interest rate is locked at the time the GFE is issued, how should the loan originator complete Lines 1, 3, and 4 in the Important dates section on the GFE?
A: When the interest rate is locked before the GFE is issued, the information in Line 1 in the Important dates section on the GFE must be completed by disclosing the date that the interest rate lock will expire, Line 3 must be completed to state the number of days the interest rate lock period is good through, and Line 4 must be completed with N/A.

6) Q: If a lender does not offer a rate lock, how should Lines 3 and 4 in the Important dates section on the GFE be completed?
A: If the lender does not offer a rate lock, then Lines 3 and 4 of the Important dates section should state Not Available or NA.

These are 2 FAQ's that reference if you do or do not lock the loan and each states that #4 can be completed with "N/A".... what date are you inserting in line #4?

ok, I reread this whole thread and NOW I get what you're asking.
By putting six days on Line 4 you're telling them they have to lock the rate at least six days prior to closing.
The use of six days was to allow you time to redisclose the TIL as I outlined above.
Rate lock mandates a redisclosure of the GFE on which line 4 will now read 'n/a'
If you do not have to redisclose the TIL as a function of locking the rate, then yes, you can close the loan whenever you like. You do not have to wait the number of days that you put on the original GFE.

Thanks TR,

You summed it up perfectly. I understand everything that was said about the important dates section. I just didn't see any guidance about how or if the number in line 4 affected the settlement date. That lack of comment made me think that it didn't affect anything, but I wanted to check with others to make sure.

Thanks to all.

We issued the GFE on Feb 1st and the loan locked Feb 2nd but we never issued a revised GFE with line 4 updated to N/A .
Other than informing the dept on miss, is there a violation I need to worry about? I think it should be rated low risk as it does not appear to be a systemic issue but a one time miss.

It may be a one time miss but it IS a violation.
Document your file as to it being a one time occurrence, train and move on.