The Reg Z proposed changes for 7/30/09 (still not finalized - right?).....state we have to give early disclosures at least 7 business prior to consummation. However, if the APR changes then we need to redisclose at least 3 business days prior to consummation. If I give the early disclosures on Monday (hand delivered), and then make changes on Tuesday and redisclose (hand delivered)....what's my waiting period for consummation? Does the fact that I redisclosed now only require 3 business days and I'm no longer concerned with the originally required 7? If so, my loan could close sooner than the originally required 7 in this scenario....as I could close on 3rd business day which would be Friday. I can't find anything in the write-ups and proposal that indicates a concern with the original 7 days if I redisclose, it only says I can't close before the 3rd business day. Trying to determine if redisclosure negates the original 7 days.....?

You are right that the rules are not finalized. The comment period has ended, but we haven't seen a regulation yet.

Because we haven't seen a regulation, I don't think it's appropriate to try to answer your questions. How will they define "3 business days"? Will it be like RofR where there's 3 days BETWEEN closing and funding or like HOEPA where you can fund ON the 3rd day? Could there be a waiver for some circumstances? Etc., etc., etc.

Let's wait and see what the regulation says.

Speaking of the comment period- I tried to go to the Fed Res site to read the comments but when I clicked on "View comments" it said 0 records. It seems unlikely that no one commented.

In the proposal, business day for the purpose of the delivery of early TIL disclosures is the "general rule" and redisclosure is the "precise rule". (general being the day which offices are open for carrying on substantially all bus functions and precise becing all cal days except Sun & legal public holidays)