Quick compliance trivia: in an owner‑occupied refinance, what starts the three‑business‑day Right of Rescission clock — note signing, funding, or “consummation” as defined by state law? I’ve had a file where the CD showed 6/14 but consummation (per state definition) was 6/15, and audit flagged the Notice of Right to Cancel dates; how are you documenting this to keep the file accurate while aligning with Reg Z and your counsel/investor guides?
If CD shows 6/14 but state consummation is 6/15, I memo NORC off 6/15 and cite https://www.consumerfinance.gov/rules-policy/regulations/1026/2/#a13-Interp.
Consummation controls; I attach the closing attorney’s email confirming 6/15 and set Encompass’s NORC off that, @s_martin92.
But i totally get the confusion with dates. It can be a real headache if the CD shows one thing and consummation has a different date. In my experience, it helps to have comprehensive documentation like the title company’s confirmation, which can make a big difference during audits. Have you seen any discrepancies in your other files?