You might recall that on June 17, 2021, President Biden declared “Juneteenth” a Federal holiday.
The lack of lead time and regulatory guidance initially created a lot of chaos for institutions, but this year should be much less eventful. You still need to be aware; however, that Juneteenth’s designation as a Legal Public Holiday has a direct impact on several lending and deposit compliance requirements, regardless of whether your institution is open or closed.
This year, Juneteenth (June 19th) falls on a Sunday, which means it will be “observed” on the following Monday, June 20th. For Regulation Z requirements that use the “precise” business day definition, June 20th is considered a business day. This includes rescission periods, wait times associated with the Loan Estimate, Closing Disclosure, Escrow Account Cancellation Notice or High-Cost Mortgage Disclosures, etc.). For requirements that use the “general” business day definition, it depends on whether your institution will be open for substantially all business functions. In other words, if you are open on June 20th, it is a business day and, if you are closed on June 20th, it’s not a business day.
For Regulation CC, however, the definition of a business day specifically states that, if any of the five legal public holidays mentioned by a specific date (New Year’s Day-January 1, Juneteenth National Independence Day-June 19, Independence Day-July 4, Veteran’s Day-November 11, or Christmas-December 25) fall on a Sunday, the next Monday is not a business day. So, for Regulation CC purposes, June 20th is not a business day, whether you are open or not.
Check out the June 2022 edition of our magazine, Banking on BCC, for a full rundown of “business days” and their effect on various compliance requirements.
Published
2022/05/31