Q: Has the Bureau clarified whether the periodic statement has to be delivered or placed in the mail within four business days or four calendar days?

A:  Section 1026.41(b) requires that the periodic statement be delivered or placed in the mail no later than a reasonably prompt time after the payment due date or the end of any courtesy period. Delivering, emailing or placing the periodic statement in the mail within four days of the close of the courtesy period of the previous billing cycle generally would be considered reasonably prompt.

 

CUNA members have frequently asked for clarification regarding whether that means four calendar days or four business days.  We have now heard from the Bureau in response to an inquiry that since comment 41(b) uses "day" instead of "business day" and since "day" is not defined in Reg Z, but "business day" is a defined term in Reg Z, it's safe to assume that "day" in this context means calendar day.