Most Popular Compliance Content
E-statements & ESIGN Compliance
06/15/2009
We are in the process of implementing e-statements and I am concerned if the process our vendor will use to comply with ESIGN's demonstrable consent is adequate. The e-statement will be delivered to the customer via an email with a PDF attachment to their current address. Customers will enroll for e-statements on our website. During the enrollment process at the bottom of our e-statement agreement there is a box for them to click that reads "I agree to the listed terms". Further down and to the right of this is the statement "Click here to see a sample document". Our vendor does not track each customer’s request to see that sample document; however they do track the customer's acceptance of the listed terms. There is a blurb in the agreement that states by clicking the "I agree to the listed terms" you certify that you have clicked on the sample document and you are able to open, read and print the sample E-statement. Is this process enough to prove demonstrable consent under ESIGN given that we are delivering the statement via an email in a PDF attachment?
Successful Training Techniques
06/15/2009
Credit Score Disclosure -Interim Construction Loan
06/15/2009
We are unsure whether the Disclosure of Credit Score required by Section 212 of the FACT Act would include an "Interim Construction Loan" to a consumer, secured by a 1-4 family residence, which will become their homestead at completion. The section mentions everything but this type of loan.
ECOA Applicability - Joint Vs Individual Credit
06/15/2009
Under ECOA does determination of joint vs. individual credit apply to all loans, or just to consumer loans?
Appraisal Rules
06/08/2009
I need information regarding the rules for appraisals. We were told that we need a new appraisal on every real estate transaction we do, or we have to have some type of third review. Can you please let me know where I can find this information?