REGULATION Z
TRID timing: business days, Loan Estimates, and Closing Disclosures
TRID date math is deceptively easy to get wrong because Regulation Z uses a general business-day definition for one deadline and a specific definition for several waiting and receipt periods.
The general definition
For the three-business-day Loan Estimate delivery deadline, a business day is generally a day on which the creditor's offices are open to the public for substantially all business functions. The creditor calendar therefore belongs in organization settings.
The specific definition
For the seven-business-day LE wait, deemed receipt, and CD waiting period, every calendar day counts except Sundays and the legal public holidays in 5 U.S.C. 6103(a). Saturday usually counts.
The actual fixed-date holiday controls. When July 4 falls on Saturday, the observed Friday closure does not automatically become excluded under this specific definition.
Receipt versus sent date
A sent date is not always the operative received date. The review should preserve actual receipt evidence where available and separately model deemed receipt. Corrected disclosures require their own trigger analysis.
Why the software does not declare legal liability
A computed variance is a compliance finding for review. Coverage, valid changed circumstances, emergency waivers, delivery evidence, and restitution require lender policy and legal/compliance judgment.
Primary references
Last methodology review: July 14, 2026. Source requirements and vendor capabilities change; verify current text before relying on it.