Impact of Juneteenth on Certain Mortgage Requirements

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The Consumer Financial Protection Bureau (CFPB) released an interpretive rule to assist the mortgage industry in determining whether to treat June 19 as a federal holiday or a business day for purposes of compliance with certain time-sensitive borrower protections.

Regulation Z of the CFPB’s mortgage rules establishes timing requirements, calculated in business days, for when borrowers must receive certain disclosures and when borrowers have the right to cancel some mortgages.

According to the CFPB, if the relevant time period began on or before June 17, then June 19 was a business day. If the period began after June 17, then June 19 was a federal holiday.  The timing requirements are related to rescission of closed-end mortgages and the TILA-RESPA integrated disclosures (TRID).  

Additionally, the interpretive rule explains that creditors are not prohibited from providing longer time periods than required, so if a time period began on, or prior to, June 17, 2021, creditors could still consider June 19, 2021, a federal holiday. Friday, June 18, the day of federal observance for the 2021 Juneteenth holiday, was considered a business day because when a federal holiday falls on a Saturday, the day of federal observance is considered a business day for these time-sensitive consumer protections.  

Read the interpretive rule here.

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