[Mary Frances]

We need clarification please. If a loan closes February 10th would the first payment be due March 10th or March 12th? There has been some discussion that because February is only 28 days that the 1st payment has to be “pushed out” so that it is exactly 30 days until the 1st payment.
I have look in Reg. Z but can not find anything that requires exactly 30 days before the first payment is due.
Thank you

[jholzknecht]

Mary,

Regulation Z generally does not require any particular period of time from origination to the due date of the first payment. Some provisions in Regulation Z require substantially equal payments; but those provisions allow flexibility for long or short odd days until the first payment.

Your state law may require a 30-day period to the first payment date, so check with your bank counsel on that issue.

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