The initial Closing Disclosure for a covered non-timeshare mortgage is hand-delivered to the consumer Tuesday, June 9. The lender proposes consummation Thursday, June 11. No valid emergency waiver or holiday applies. May consummation occur Thursday?
Correct Answer
B) Too early: the consumer must receive it 3 business days before closing
B. Thursday is too early; Friday, June 12 is the earliest ordinary date. Hand delivery establishes Tuesday receipt without a mailing presumption. Wednesday, Thursday and Friday are the three days following receipt. Scope and exceptions: Timeshares and some subsequent corrections have different rules. A waiver requires the specific bona fide personal financial emergency conditions, which this scenario excludes. Source: Section 1026.19(f)(1)(ii)–(iv); comment 19(f)(1)(iii)-1 — https://www.consumerfinance.gov/rules-policy/regulations/1026/19/
Why This Is the Correct Answer
B. Thursday is too early; Friday, June 12 is the earliest ordinary date. Hand delivery establishes Tuesday receipt without a mailing presumption. Wednesday, Thursday and Friday are the three days following receipt. Scope and exceptions: Timeshares and some subsequent corrections have different rules. A waiver requires the specific bona fide personal financial emergency conditions, which this scenario excludes.
Why the Other Options Are Wrong
Option A: Acceptable where the consumer signs a waiver at the closing table
A routine signature at closing is not a qualifying emergency waiver.
Option C: Too early: the period is 7 business days, so Thursday 18 June is first
Seven days is not this Closing Disclosure waiting period.
Option D: Acceptable: hand delivery removes the waiting period altogether
Hand delivery removes receipt uncertainty, not the required wait.
Exam Tip
Separate receipt method from the waiting period following receipt.
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