The 7th day of the waiting period is 4-18-12. The customer wants to come in before to sign paperwork and then we just not fund until the 18th. Can we do this?

Difficult. When we had real estate closing and one of the borrowers was overseas or otherwise not present, the final closing with borrowers who were present was conducted on the correct date and we had to have a telephone call with the absent borrower at closing. "Proof of life" so to speak. It may be doable but I'd get counsel's blessing before I would fall on my sword, so to speak.

It may be doable but I'd get counsel's blessing before I would fall on my sword, so to speak.

Definitely follow this advice, but in most states the date of consummation is when the loan documents are signed, not when they are dated or when funds are disbursed so IMHO you would be in violation of MDIA because the date the consumer signed the loan documents is the date you closed the loan.

I agree...docs being signed makes it a done deal, the bank is legally obligated to fund under the signed contract.