When a ROR notice is required, is there also a requirement to have the borrower send/deliver the signed notice stating they are not exercising this right? Of course we would have them sign the notice if they chose to exercise the right, but I think we are causing ourselves unnecessary work by requiring the borrower to send the notice back when they are not exercising the right.
That is a practice that is becoming less common among FIs. There is no regulatory requirement to have them sign the ROR notice either for acknowledgment of its receipt or their confirmation they have not rescinded.
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The opinions expressed are mine and they are not to be taken as legal advice.
However, if you sell your loans on secondary, the investors often require use of the ROR form that uses signatures. And, unlike arguing with an examiner, it's the investor's ball so you have to play by their rules, regulatory or not.