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3 hours ago, Chibearsv said:

Yes, normally a Saturday normally counts as a "rescission day" but the law says that we can't count a day that is a "legal Federal holiday" as a rescission day.  So as an example, a borrower that signed to re-finance his home on Wednesday has a right to cancel the transaction (rescind) within 3 days (Thursday, Friday, and Saturday) if he doesn't rescind by Saturday, we fund his loan on Monday, normally, which is what all of his documents say I'm going to do.  Now I can't legally count Saturday as a rescission so by law, I'm not allowed to fund his loan until Tuesday.  This same problem will effect loans closing Thursday and Friday as well.  There's no way we can explain this to a borrower that will make them think we are anything but liars since it's too preposterous to be true.

I get you now. I'm surprised to be honest that the process that enacted this holiday at 1 day's notice (congress?) or some team behind the process, wouldn't have thought of the impact on your industry and others like it. I'd be surprised that this Saturday will count as a rescission day.

Having said that, that doesn't help you or your clients. And from experience, I know that 1 day won't do to update most software systems or even processes. I agree with you 100%, more notice should have been given.

As for what the holiday is commemorating, and that value of that, debating that will just get the thread hidden I'm afraid.

 

3 hours ago, sonarman81 said:

Shouldn’t they know about the holiday? 

The very words spoken before countless avalanches of angry emails!

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Mods seeing this thread.....  

I 100% support the holiday but the execution of it and allowing it to mess with the mortgage process was a very dumb oversight.  IMO drop the politics…no need to drag them into this. The holiday is

If new federal holidays are created using an exponential function (to honor every group in the Woke Pantheon), I would calculate there will be no workdays left by 2040. Hopefully the robots will

3 hours ago, sonarman81 said:

Shouldn’t they know about the holiday? 

The tricky part is that the documents say they're getting money on Monday (which they aren't) since we didn't know it was a holiday on Wednesday when they signed all the closing docs.  If I told you on Wednesday that I was going to send $300,000 to you mortgage company to pay off your old loan on Monday, and then Friday notified you that due to circumstances, your mortgage company won't get paid off until Tuesday, you wouldn't be happy and you wouldn't think I knew what I was doing.

 

3 hours ago, Ryan said:

I get you now. I'm surprised to be honest that the process that enacted this holiday at 1 day's notice (congress?) or some team behind the process, wouldn't have thought of the impact on your industry and others like it. I'd be surprised that this Saturday will count as a rescission day.

Having said that, that doesn't help you or your clients. And from experience, I know that 1 day won't do to update most software systems or even processes. I agree with you 100%, more notice should have been given.

As for what the holiday is commemorating, and that value of that, debating that will just get the thread hidden I'm afraid.

Normally, I would not be afraid to fight this issue with the regulators because of its stupidity but the bigger problem is that the investors attorneys have already opined and notified us that if we count Saturday, our loans will be unsaleable.  That's a big money losing problem.

Your initial assessment of my thread is accurate, has nothing to do with the holiday itself, just the lack of forethought by lawmakers.  

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8 minutes ago, Chibearsv said:

Normally, I would not be afraid to fight this issue with the regulators because of its stupidity but the bigger problem is that the investors attorneys have already opined and notified us that if we count Saturday, our loans will be unsaleable.  That's a big money losing problem.

Yeah it looks like a real pain in the arse to say the least. It certainly looks like a hurried decision to make the day a holiday, a business day for some industries. It should have been decided months ago or else announced for commencement next year. I think most people would have been understanding. Best of luck is the only other thing I can say I'm afraid! I'm unfortunately aware, recently, of what it's like to have important business rules change with 24 hours or less notice. It ages you.

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No surprise that the all knowing politicans screwed this up.  None of them have ever run a business and had to meet a payroll, pay suppliers, etc. etc.  They make insane policies without any thought of how they impact various facets of the country they so ineptly govern.  They've all feed at the public trough after graduating from their genius colleges.

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3 hours ago, El Presidente said:

nice work gents keeping this thread on track :clap:

Lol.   Methinks you posted the wrong video.   

  

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Update, an announcement from the regulatory enforcement agency.  Finally, guidance!  This was issued after close of business on Friday:

Statement by CFPB Acting Director Dave Uejio on Impact of the Juneteenth National Independence Day Federal Holiday on Residential Mortgage Closings

WASHINGTON, D.C. — Today, Consumer Financial Protection Bureau (CFPB) Acting Director Dave Uejio issued the following statement:

President Biden’s signing of the Juneteenth National Independence Day Act into law yesterday afternoon is a cause for celebration. Juneteenth is a moment for us to commemorate the emancipation of those enslaved. I am proud that we as a country are taking concrete steps to recognize and heal from the legacy of slavery, even as I recognize that there is much more work to do. 

The CFPB, along with the other Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA) regulators, is aware of concerns regarding implementation of the new Juneteenth Federal holiday, particularly as it relates to mortgage lender compliance with the Truth in Lending Act and TILA-RESPA Integrated Disclosure (TRID) timing requirements. The CFPB recognizes that some lenders did not have sufficient time after the Federal holiday declaration to consider whether and how to adjust closing timelines. The CFPB understands that some lenders may delay closings to accommodate the reissuance of disclosures adjusted for the new Federal holiday. The CFPB notes that the TILA and TRID requirements generally protect creditors from liability for bona fide errors and permit redisclosure after closing to correct errors.
Any guidance ultimately issued by the CFPB would take into account the limited implementation period before the holiday and would be issued after consultation with the other FIRREA regulators and the Conference of State Bank Supervisors (CSBS) to ensure consistency of interpretation for all regulated entities.
 

The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and by empowering consumers to take more control over their economic lives. 

 

Summary analysis: "We'll have a committee meeting in the future to determine if we will fine you for violating the rules that we aren't going to give you clarity on right now".
 

 

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4 hours ago, Chibearsv said:

The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules,

Do they even read their own press releases?       They have not even made up the rule yet, how can they know it will be "effective"?   Did they have a fortune teller or seer in the room who could see the future?  😀

This language probably was generated by a committee of more than ten folks spending hours in a room parsing over each word.

How do I know this?   Because I used to be in .gov and in the room for hours and hours and hours while the attorneys parsed every word of documents--by the time they are finished with any document it becomes all boilerplate and no real content.

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2 minutes ago, Cairo said:

Do they even read their own press releases?       They have not even made up the rule yet, how can they know it will be "effective"?   Did they have a fortune teller or seer in the room who could see the future?  😀

This language probably was generated by a committee of more than ten folks spending hours in a room parsing over each word.

How do I know this?   Because I used to be in .gov and in the room for hours and hours and hours while the attorneys parsed every word of documents--by the time they are finished with any document it becomes all boilerplate and no real content.

It had to take years to come up with their tagline at the end.

 

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28 minutes ago, Chibearsv said:

years to come up with their tagline at the end

The only way to win in some of these bureaucracies is just to outlast the opponents.    It was when I hit the twenty year mark that some of the worst obstacles retired and we could actually get something done.     The first step is to recruit your team of attorneys so you can keep the other attorneys out of the room. 😀

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On 6/18/2021 at 5:00 PM, Chibearsv said:

The tricky part is that the documents say they're getting money on Monday (which they aren't) since we didn't know it was a holiday on Wednesday when they signed all the closing docs.  If I told you on Wednesday that I was going to send $300,000 to you mortgage company to pay off your old loan on Monday...

Massively ignorant question; if the lenders are closed on Monday, aren’t the mortgage companies closed as well?

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4 minutes ago, Chas.Alpha said:

Massively ignorant question; if the lenders are closed on Monday, aren’t the mortgage companies closed as well?

No, the holiday was actually officially Saturday and observed as a day off by the federal government agencies on Friday. We aren’t a broker, we are a lender and tend to have the same days off as the banks. I’m pretty sure the banks didn’t close on either Friday or Saturday since they had no notice to give their customers.
 

Unfortunately in our industry, the decisions or interpretations of the rules by the investors (banks, FNMA, FHLMC, GNMA generally) pretty much determine how a mortgage company must operate. If they decide we broke a rule, they aren’t going to buy a loan we originated, that creates losses for us that are tough to absorb and lowers our ratings with them. 

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4 minutes ago, Chibearsv said:

 

Unfortunately in our industry, the decisions or interpretations of the rules by the investors (banks, FNMA, FHLMC, GNMA generally) pretty much determine how a mortgage company must operate. If they decide we broke a rule, they aren’t going to buy a loan we originated, that creates losses for us that are tough to absorb and lowers our ratings with them. 

Fortunately, or unfortunately depending on your perspective, my industry (construction) doesn’t observe ANY Federal holidays, save for Christmas Day and Thanksgiving. I have worked on both of those days during my career... 😔

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Fortunately, or unfortunately depending on your perspective, my industry (construction) doesn’t observe ANY Federal holidays, save for Christmas Day and Thanksgiving. I have worked on both of those days during my career... 😔
 

Same here. My holidays are when the job is complete. Or I put my foot down and get these next 2 weeks off. 😃

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14 minutes ago, Chas.Alpha said:

Fortunately, or unfortunately depending on your perspective, my industry (construction) doesn’t observe ANY Federal holidays, save for Christmas Day and Thanksgiving. I have worked on both of those days during my career... 😔

I'm thankful that I'm able to take advantage of those holidays sometimes and escape out of town for 3 and 4 day weekends.  Week long vacations without working are pretty much out of the equation for me so I do enjoy an extra forced day off here and there.  I honestly wouldn't take the time off otherwise.

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On 6/18/2021 at 2:06 PM, Woody Hayes said:

There is no end to the phony pandering to different races by these vile politicans.  It's all a phony effort to appease certain groups so they'll continue voting for them.  Thus our so called leaders can stay in office and continue taking their payoffs and enriching themselves.  Do you actually think Biden, Harris, Pelosi, et al were ever concerned about having a holiday for the freeing of the slaves?  The only thing that kept them up at night was how could they stay in power and keep the money supply coming in.

Now they'll push reparations in the trillions and taxpayers will foot the ever increasing deficit.  Competent economists estimate we have given 22 trillion to minority communities since the signing of the Great Society laws.  When will it end?  Never.

 

 

   *Just to let you know - as soon as the slaves were supposedly "freed" (and the Juneteenth Holiday is for the slaves that were deliberately informed 2 years later that they'd been freed) the Slave Owners were IMMEDIATELY PAID REPARATIONS then and there for their loss of free revenue. Even in Haiti, when they'd freed themselves from French rule only to have the Americans march into their country in 1820 and dissolve their parliament at gunpoint - they were made to pay reparations to France right then and there for the loss of revenue. Why does it always have to be a point of contention to PAY THE VICTIMS SOME KIND of reparations for what they'd suffered??? Huh?? It hasn't been done YET. Plus I don't know WHERE you're getting this $22 trillion to minority communities since the Great Society laws. They wouldn't be in the blighted conditions it would seem if so. That is due to this fake, false phony "drug war".

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On 6/19/2021 at 8:21 AM, Mickey D said:

How To Celebrate Juneteenth:

Step 1: Remind people that it only exists because a white Union General named Gordon Granger had to go to Galveston Texas on June 19, 1865 to tell the slaves they were free because their racist southern Democrat masters conveniently forgot to tell them about the Emancipation Proclamation that had been made law by Republican President Abraham Lincoln more than 2 years prior on January 1, 1863.

Step 2: Repeat Step 1 as necessary.

Look it up if you don't believe me.

Knowledge is power.

 

I'm unclear on the point you're trying to make.  I believe what you posted to be factual (except for the "How to Celebrate Juneteenth" bit).  What knowledge are we supposed to learn from this post?

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Guys, the complaint here really seems to be the incredibly short notice not the holiday itself. There no question that one day notice is ridiculous. What hasn’t been mentioned is why this happened. And the reason is unfortunate and simple: the US Senate has the most arcane, undemocratic rules of any legislative body found in developed democracies.

The resolution for Juneteenth, which passed unanimously in both houses, was held up by a single Senator from mid-2020 until early last week (Ron Johnson, R-WI), as is his right under Senate rules. His decision to relent now instead of two months or two weeks ago was cynically aimed at precipitating the exact scenario @Chibearsv understandably is pissed about, aimed obviously at the other party.

So let’s aim the animus where it is really deserved - one dude in a ridiculously anachronistic house of Congress, without whom this would’ve happened months ago.  

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Just now, MrBirdman said:

Guys, the complaint here really seems to be the incredibly short notice not the holiday itself. 

Bingo Bird. 

Unless Cuba is involved somehow (and it isn't), debate as to the rights and wrongs of the public holiday itself or compensation etal can be taken to  www.anywherebuthere.com 

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1 hour ago, Cletus said:

 

I'm unclear on the point you're trying to make.  I believe what you posted to be factual (except for the "How to Celebrate Juneteenth" bit).  What knowledge are we supposed to learn from this post?

Any time I see a post along those lines I assume it's an attempt to pretend the "Great Switch" never occurred.

https://www.livescience.com/34241-democratic-republican-parties-switch-platforms.html

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18 hours ago, Bri Fi said:

@cigcars does all caps mean you’re yelling? 

     *As it's not all caps, no...only emphasizing where needed

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