ROR & TIL Redisclosure - Timing of Funds Disbursal

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Question:

My question involves a redisclosure of TIL combined with right of rescission. Using a real life 2010 calendar example, the redisclosed TIL was put in the mail on 4/2/10 (a Friday). Allowing three days mail time and three days for the TIL puts us to the following Friday, 4/9/10. Do I have then to wait until the following Saturday (the 10th) to mail the right of rescission forms, thereby allowing another three days mail time and the three days right of rescission, allowing me to disburse on 4/19/10?

Answer:

If you mailed the redisclosure on 4/2/10 you can close on 4/9/10; the ROR would expire three business days after the last to occur of that date, the loan's consummation date, the date material disclosures are delivered, or the date the ROR form is provided. The redisclosure waiting period and the ROR waiting period cannot run concurrently.

First published on BankersOnline.com 6/14/10