John Zasada, Compliance Consulting Director, Financial Institutions Group

On Aug. 5, 2021, the Consumer Financial Protection Bureau (CFPB) released an 11-page interpretive rule to assist lenders in determining Regulation Z timing requirements related to rescission of closed-end mortgages and the TILA-RESPA Integrated Disclosures (TRID) in light of the new Juneteenth federal legal public holiday. The interpretive rule clarifies that, if the relevant closed-end rescission or TRID time period began on or before June 17, 2021, then June 19, 2021, is considered a business day. If the relevant time period began after June 17, 2021, then June 19, 2021, is a federal holiday. Note: nothing prohibits lenders from providing longer time periods. Therefore, it would also be compliant for lenders to have considered June 19, 2021, a federal holiday for purposes of these rules.

If you have questions about this new interpretive rule, contact Doeren Mayhew’s regulatory compliance specialists today.