If we wanted to use Saturday as a business day for purposes of resetting the clock faster when borrowers don't commit within the 10-day time frame, what would we need to prove? The rule says "The 10-business day requirement for settlement costs essentially provides that the GFE will be available for 2 WEEKS, thereby providing borrowers with sufficient time to shop among various providers." Would shortening this period by 2 days be acceptable?

The 10 days are business days (3500.7(c)). RESPA defines a business day as follows.

3500.2

Business day means a day on which the offices of the business entity are open to the public for carrying on substantially all of the entity's business functions.

If you are not open on Saturdays for substantially all of your business functions then you cannot include Saturday as a business day for RESPA timing requirements.

Yes Dan, there's the rub...what does "substantially" mean? I can't find any relevant commentary or rulings.

If all you provide is deposit services then you aren't open for substantially all of you business functions.

As a "rule of thumb" you should offer all services on Saturday that you do Mon-Fri.

Dan,
I agree with the "all services", but we only have 15 out of 150 branches open on Saturday. Those that are open do offer "all services". I believe that this would mean we count Saturday, but I can't find anything that discusses this issue. I would appreciate any opinions and help on this.
Thanks

Not sure I can give you official guidance but only an opinion.

I assume those 15 branches are in one market locale. And I assume from your statement that they take applications, underwrite, decision and close mortgage loans on Saturday. If that's the case then that market is open and Saturday would be a business days for applications received in that market. I don't believe you would have to include Saturday as a business day for those branches in the other markets that are not open.

Thanks for the quick response.
The branches are located in 2 geographic regions, but I doubt our mortgage folks would want to give differing instructions by region due to the confusion it would cause. Thanks for your help.