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Applications Online
Answer by Andy Zavoina and Richard Insley, BOL Gurus
Guru Bio
Question: We want to take real estate mortgage applications online. Do we have to follow E-sign rules to do this?
Answer by Andy Zavoina: Not really. The new rules under Reg B which deal with the collection of the Government Monitoring Information, exempt these from E-sign. Here is information from a recent webinar on E-sign and other electronic delivery rules.
When provided in e-form, the following are exempted under §§202.5, 202.13, 202.14
- request for race, color, religion, national origin, sex for a self test 202.5(b)(1)
- request to designate title (Mr. Ms, Mrs.) 202.5(b)(2)
- request for marital status (married, unmarried, separated) 202.5(d)(1)
- alimony notice 202.5(d)(2)
- request for GMI 202.13(a)
- appraisal notice 202.14(a)(2)(i)
Answer by Richard Insley:
Has HUD ever provided guidance on the threshold for E-sign approved RESPA disclosures? If not, this could be the first roadblock.
First published on BankersOnline.com 4/28/08
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