The High Risk Home Loan Act does not expressly contain any timing requirements for either the certificate of completion or the waiver of participation in the Mortgage Awareness Program (except that the borrower must wait at least two business days after receiving the lender’s notice of the program before signing a waiver, 815 ILCS 137/110(h)). However, we think a strong argument can be made that the Act’s intent is for the borrower to sign either the certificate or waiver before the loan closing. We strongly recommend that one or the other be signed and dated on or before the date of the loan closing, regardless of when you place this document in your loan file, in order to avoid any later compliance issues (particularly with respect to UDAAP).