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What Is an Electronic Document? (Part II)
by Richard C. Insley, CRCM
When the Federal Reserve Board issued the September 14, 1999 e-Reg proposals, they produced a list of the various "disclose in writing" rules embedded in the 5 regulations subject to the proposal. This list did nothing to affect the substance of the regulations. Instead, the list is useful as a checklist for electronic and e-sign compliance. Each disclosure on the list is now eligible for e-delivery under E-SIGN.
Part II (Part I appeared in the last issue. - Volume 5, Number 13)
Consumer Leasing; Regulation M
- Disclosure at lease signing including information about payments, early termination, purchase options, and fees such as taxes and insurance
- Disclosures when leases are renegotiated or extended
Truth in Lending; Regulation Z - Closed end credit
- Pre-consummation stage:
- ARM "program disclosures"
- "CHARM" booklet
- Estimated cost disclosures (three days after application)
- Transaction disclosures:
- "Section 32 disclosures"
- Disclosures for reverse mortgages
- Servicing disclosures
- Annual notice of ARM rate adjustment
Truth in Savings; Regulation DD
- Account-opening disclosures
- Notice of change in account terms
- Notice of maturity for certificates of deposit
- Periodic statements of account activity
Each of the disclosures listed are based on the existing requirements in compliance regulations. The existing requirements are paper-based, i.e. they were developed with the idea that disclosures, like most business communications, were made on paper. The e-sign bill and electronic developments simply make it possible to provide the same information using electronics instead of paper.
Richard C. Insley, CRCM, President, APR Systems, Inc.
richard@aprsystems.com - http://aprsystems.com - (804) 271-2234
Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 14, 12/00
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