We did a PEL and no final disclosure giving the consumer the right to cancel was provided. Given the statement below- if we give the final disclosure now and they don't rescind three days from when disclosed- are we at least out of the rescission nightmare?
(d) Consumer's right to cancel. The consumer may cancel a private education loan, without penalty, until midnight of the third business day following the date on which the consumer receives the disclosures required by §1026.47(c). No funds may be disbursed for a private education loan until the three-business day period has expired.

If you have disbursed funds there is no way to un-ring this bell.

Thank you. That is what I thought- but hope still springs eternal.