Isn’t Chicken Fried Peanut Butter (cfpb) easier to swallow than Consumer Financial Protection Bureau (CFPB)?
How long does it take to digest cfpb? How long does it take to digest CFPB? THREE BUSINESS DAYS!!!
Let me try to assist your digestion of this. Under the Three-Day Closing Disclosure Rule, in order for a closing to be held on Thursday, evidence of disclosures are due on Monday. For a closing on Monday, disclosure must be received by the preceding Thursday. Tuesday, the preceding Friday, and so forth. The three day rule is not a 72 hours rule, but a day rule.
The three day rule starts on the day of consummation. Much shorter than the nine months that you were thinking, huh.
Consummation is the day the consumer becomes contractually obligated on the loan, typically the day of closing. Once that day is determined the count must go backward three days. For a Thursday closing, go back Wednesday, Tuesday, Monday. Monday is the day all disclosures are due, and evidenced.
Evidenced means physical delivery of the disclosures, i.e. receipt, e-mail confirmation, system log or e-sign. Just mailing the disclosures is not enough evidence to prove receipt of the disclosure. If the disclosers are made during a holiday, allow add extra day, four business days, but proof of delivery is also required. Business days are Monday through Saturday. Sundays and public holidays are not counted.
If there are changes to the disclosures, the days start over. So does the pressure!
Disclosures may be made by the creditor or settlement agents, which ever the lender prefers. However, communication between the creditor and settlement agent must be maximized as Closing Disclosures and Loan Estimates and must meet these and other requirements discussed in past “Chews.”
You know that being the settlement agent, all blame will be on your shoulders as you are the last person seen by the borrower, so be sure communication is superb.
If by chance you’re dyslexic like me, be sure to have someone else count the days; 1-2-3, You’re Free!
Chew on this for awhile, but “I’ll be back!”