TRID Business Days

Then the other thing I do need to mention here is this business day and this is why I think people like me have a job, why you have compliance officers because we can't just say a day is a day. Truth and lending where TRID resides, they decided to take the business day and say, "Well, sometimes we mean this and sometimes we mean that." The good news for all of you, as you go through the manual here today, in parentheses... Anytime we say, "Business day," it's going to say one of these two, precise or general, in parentheses right after it and so you'll know. If you go back to page one and say, "All right, which one is that again?" they're not all too complicated. If we say, "Precise business day," it means you count all days except for Sundays and federal holidays. All days except for Sundays and federal holidays, regardless of whether you're open, count them.

The general business day works like this. It's only days that you're open for substantially all business functions. Now, some of you listening, I know you might be open on a Saturday but are you fully open? If you're not fully open, the drive-up might be open, maybe you got a teller, maybe even a loan officer there but you don't run the business on Saturdays, then you don't count that one. Here's the deal. Both of these work in your favor. In other words, use the general business data to buy yourself more time for certain disclosures to get out the door. The precise business day cancels faster delay periods, like the right of rescission, like some of the waiting periods and again, that'll make more sense as we work our way through the program and as you learn more about the mortgage compliance requirements.