Juneteenth Clarified For Compliance Purposes

August 13, 2021 at 9:08 am Leave a comment

Yours truly has a busy day today. But I wanted to give you a heads up on an announcement that I almost missed when it first came out. As I’m sure many readers of this blog recall, when President Biden signed a bill proclaiming Juneteenth a national holiday. The bill took effect immediately. As a result, as drafted, June 17th could not count as a business day for certain RESPA and TRID disclosures required in the federal law. Many a lender spent a long couple days reconfiguring disclosures.

To its credit the CFPB has issued this interpretive guidance clarifying compliance issues for this period. Specifically, in its guidance the CFPB stipulates that “in the context of the 2021 Juneteenth Federal holiday and the affected closed-end rescission and TRID provisions, if the relevant time period began on or before June 17, 2021, then June 19, 2021 is a business day for purposes of the specific business day definition. If the relevant time period began after June 17, 2021, then June 19, 2021 is a Federal holiday for purposes of the specific business day definition.”

I would keep this guidance in the file, you know someone down the road is going to make an issue out of this. On that note, enjoy your weekend and I’ll be back on Monday.

Entry filed under: Compliance, Mortgage Lending, Regulatory. Tags: , .

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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