A creditor receives a TRID application on Monday, April 6. Its offices are open to the public for substantially all business functions Monday through Friday only. No holiday falls in this period. For the initial Loan Estimate, which deadline and business-day definition apply to delivery or mailing within three business days after receipt?
Correct Answer
B) Thursday, April 9: use days open for substantially all business functions
B. Thursday, April 9, using the general business-day definition. Exclude receipt day: Tuesday is day one, Wednesday day two and Thursday day three. The calculation tests both the date and the correct definition. Scope and exceptions: This is the initial delivery-or-mailing deadline, not proof of receipt. Other TRID periods use a different definition. Limited services at an open office do not necessarily satisfy the business-function test. Source: Section 1026.2(a)(6); comment 2(a)(6)-1 — https://www.consumerfinance.gov/rules-policy/regulations/1026/2/ Section 1026.19(e)(1)(iii)(A) — https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
Why This Is the Correct Answer
B. Thursday, April 9, using the general business-day definition. Exclude receipt day: Tuesday is day one, Wednesday day two and Thursday day three. The calculation tests both the date and the correct definition. Scope and exceptions: This is the initial delivery-or-mailing deadline, not proof of receipt. Other TRID periods use a different definition. Limited services at an open office do not necessarily satisfy the business-function test.
Why the Other Options Are Wrong
Option A: Friday 10 April, since the day of receipt is excluded from the count
Excluding Monday does not add a fourth day.
Option C: Wednesday 8 April, counting every calendar day except Sunday
Wednesday is only the second day after receipt.
Option D: Thursday 9 April, because Saturday counts and Sunday does not
The date coincides, but its stated definition is wrong for this deadline.
Exam Tip
Identify the deadline before choosing a business-day definition.
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