Q: For purposes of the right of rescission under Regulation Z (Truth in Lending Act), is July 3, 2026, considered a business day?
A: For purposes of the right of rescission, Regulation Z defines a “business day” as all calendar days except Sundays and the federal legal public holidays listed in 5 U.S.C. § 6103(a). This definition is uniform and does not vary based on whether a financial institution, the U.S. Postal Service (USPS), or other businesses are open or closed.
Importantly, for certain holidays — including Independence Day — the regulation treats only the specific date listed in the statute (July 4) as a legal public holiday. The date the holiday is observed does not change this analysis. Even if a bank, the USPS, or other offices close or observe the holiday on a different day (such as July 3), that observed date is still considered a business day for rescission purposes.
As a result, when calculating the three-business-day rescission period, institutions should exclude only the actual federal holiday (July 4), not any observed or alternate closure dates. Systems or vendors that exclude both July 3 and July 4, 2026, are taking a conservative approach that extends the rescission period beyond what Regulation Z requires. While this is permissible from a customer-protection standpoint, it may unnecessarily delay loan funding.
In short, the rescission timeline is driven by the Regulation Z definition of “business day” in 12 CFR 1026.2(a)(6) and its official interpretations — not by operational factors such as postal schedules or observed holidays. Note that this same definition of “business day” applies for purposes of providing the Closing Disclosure under the TILA-RESPA Integrated Disclosures rule.
