CFPB Issues Interpretive Rule on Juneteenth-Related Mortgage Closing Delays

The Consumer Financial Protection Bureau last Thursday issued a long-awaited interpretive rule providing clarity on how the newly-enacted Juneteenth holiday affected the timing of disclosures required for mortgage transactions in process. President Biden earlier this summer signed legislation recognizing Juneteenth as a new federal holiday. Since June 19 fell on a Saturday, the federal government observed the holiday on June 18. However, given the short timeframe between the law’s enactment and the observed federal holiday, questions arose about how it would affect mortgage closings.

The guidance addresses Regulation Z timing requirements related to rescission of closed-end mortgages and the TILA-RESPA Integrated Disclosures. It clarifies that “if the relevant closed-end rescission or TRID time period began on or before June 17, 2021, then June 19, 2021, was considered a business day, but nothing prohibits creditors from providing longer time periods. Therefore, it would also be compliant for creditors to have considered June 19, 2021, a Federal holiday for purposes of these provisions.”

The interpretive rule will take effect upon publication in the Federal Register. ABA has published a members-only staff analysis. Read the interpretive ruleRead ABA's staff analysis  For more information, contact ABA’s. Rod Alba or Sharon Whitaker.

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