Unless these are courtesy copies and traditional paper docs are also delivered within regulatory time limits, you have several systemic violations of TILA and RESPA. E-delivered docs only "count" when you have the applicant's informed consent in advance. If the e-deliveries don't count, then it's just like you never gave the disclosures at all! The only way to get e-deliveries to count is to follow ESIGN's opt-in procedures.
This is more complicated than your lenders realize. Your very best bet is to purchase a copy of
Andy's seminar on this topic. Go through it once by yourself to get a firm grip on the principles involved and to consider what's the best fit for your business needs. Then, get one of the lenders appointed to what will become a small implementation task force. Have him/her review the seminar with you and lay out a rough plan. Next, the two of you can bring in your attorney (to draft the formal e-delivery agreements), operations/dp (to assure that the technology will support your business decisions), marketing (so you get the highest level of customer acceptance), and audit (to be sure you're creating a system that can be tested easily.)