The definition of a holiday is very specific under the rule. I know it cites a particular statute for those holidays, but I don’t know if it describes what happens between the actual holiday and the observed day.
One thing I’ll mention about that is in this rule, we tried not to change some of the underlying compliance requirements. The specific definition of business day doesn’t change between the current rules and this rule; the same holidays are used. Whatever you’re doing for the current specific definition of business day would apply to the TRID rule.
Same thing with APR tolerance for the revised closing disclosure. That currently applies to the Final TIL. Whatever you’re doing for the Final TIL, if you’ve looked at the compliance issues surrounding your APR tolerance of the Final TIL and already decided you’re compliant with the requirements under MDIA for that, then you should be within compliance with that provision under TRID as well.
Answered By: Richard Horn