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Timing of electronic disclosures.

Question: 
The loan estimate must be delivered or placed in the mail not later than the third business day (general rule) after receipt of the consumer's application. As long as you can document that the email was sent not later than the third business day you will be fine.
Answer: 

The consumer must receive the closing disclosure (CD) no later than three business days (specific rule) before consummation. As long as you can document that the email was sent at least six days before consummation you will be fine. In the alternative if you have documentation from the borrower acknowledging receipt of the CD no later than three business days before consummation you will be fine.
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First published on 10/20/2019

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