How Long a Loan Estimate Offer Must Remain Open

A Loan Estimate includes an expiration date for the estimated terms. Regulation Z sets a minimum period during which the consumer can indicate an intent to proceed.

The 10-business-day rule

Under 12 CFR 1026.19(e)(2)(ii), a creditor must permit the consumer to indicate an intent to proceed for at least 10 business days after the Loan Estimate is provided or placed in the mail. A creditor can offer more time, but it may not set an earlier expiration that shortens the minimum period.

What the period does—and does not do

The period gives the consumer time to compare offers and decide whether to continue. It does not mean the loan is approved, guarantee the quoted rate beyond any separate rate-lock terms, or force the consumer to proceed. If the consumer does not respond within the creditor's stated period, the creditor may treat the estimate according to the rule and its procedures.

Count business days correctly

Regulation Z uses defined business-day rules. Depending on the provision, a business day can mean every calendar day except Sundays and federal legal public holidays, or a day the creditor is open for substantially all business functions. Check the definition that applies to the specific timing question rather than counting weekdays automatically.

What the ten-business-day period does

Regulation Z treats a Loan Estimate’s estimated closing-cost terms as expired for good-faith purposes if the consumer indicates intent to proceed more than 10 business days after the disclosures were originally provided, unless the creditor specified a longer period. After that point, the creditor may use a revised estimate without a separate changed-circumstance justification for the lapse itself.

This does not mean every interest rate is locked for 10 business days. The rate may be floating or subject to a separate lock agreement. It also does not mean the creditor must wait 10 days before continuing a transaction; the consumer can indicate intent earlier. The period concerns when the estimate expires for the rule’s good-faith analysis.

How a creditor can set a longer period

If the creditor communicates an estimated-cost availability period longer than 10 business days, that longer period controls for the expiration provision. The creditor may not rely on the ordinary 10-day lapse to issue revised estimates until the longer communicated period ends. A specific date and time for estimated closing-cost expiration appears in the Loan Estimate under §1026.37(a)(13), subject to the applicable details.

The date is not the same as the Loan Estimate delivery deadline or the seven-business-day waiting period before consummation. Those are separate clocks. A good exam answer names which clock it is calculating and identifies whether the question concerns when to send the form, how long costs remain available, or when consummation may occur.

Worked calendar example

A creditor delivers a Loan Estimate on Monday and states an estimated-cost expiration date 10 business days later. If the consumer indicates intent to proceed within that period, the creditor generally cannot revise charges merely because the ten-day period elapsed; another permitted reason may be required. If the consumer waits until after the stated period, the creditor may issue revised estimates on the basis of expiration for good-faith purposes.

Business-day counting rules differ across parts of Regulation Z. Use the definition that applies to the provision, and count weekends or holidays only as the rule directs. Do not calculate from when the consumer happened to open an email if the rule measures from delivery or mailing and presumes receipt after a specified period.

Distinguish cost expiration from rate lock

The Loan Estimate includes an estimated closing-cost expiration date and time under §1026.37(a)(13). That date governs the period during which the disclosed estimates remain available for good-faith analysis, subject to the rule. An interest rate lock is a separate agreement with its own expiration and can require updated disclosures when locked.

A consumer may see a Loan Estimate with an unlocked rate; that does not mean the rate is held for the full cost-estimate period. Conversely, a rate can be locked while other cost estimates remain subject to the LE expiration and change rules. Review the rate-lock terms and the LE’s expiration information separately.

Intent to proceed and fee collection

A creditor generally may not impose fees other than a bona fide and reasonable credit-report fee until the consumer has received the Loan Estimate and indicated intent to proceed. The expiration period does not mean the creditor must collect a fee or that the borrower has accepted the loan automatically. Intent to proceed is an affirmative step defined by the rule and compliance guidance.

If the consumer waits beyond the applicable expiration, the creditor may issue revised estimates based on the lapse for good-faith purposes, but must comply with disclosure timing and other restrictions. It cannot use expiration to rewrite the transaction without providing the required revised disclosure.

Consumer and lender actions after expiration

If the consumer wants to proceed after the stated expiration, the creditor may issue a revised Loan Estimate using the expiration rule for good-faith purposes. It should clearly communicate the new estimates and follow delivery rules. The consumer can still compare offers and decide whether to proceed; expiration is not a penalty or automatic contract acceptance.

If the consumer indicates intent within the availability period, the creditor should retain the original estimate and evidence of the timing. If the lender communicated a longer period, use that expiration date. A transaction-specific change such as a requested loan change, rate lock, or changed circumstance may independently support a revision, but document the correct reason.

Exam takeaway

Allow at least 10 business days after delivery or mailing for the consumer to indicate intent to proceed. Keep this shopping period distinct from the three-business-day disclosure deadline and separate rate-lock rules.