Hello to all,
I am seeking advice for the following topic. Our Institution does not accept residential or consumer loan applications over the internet, all our applications are done in person, mail, or over the telephone. What are you doing in order to send initial disclosures (TIL and GFE) via email and at the same time comply with E-Sign? I understand the borrower must consent to electronic disclosures but how are you getting this done? Please share your practices. Thanks

We are not, it is my understanding that e-mail is not an acceptable delivery method unless your bank is E-sign compliant.

Just my opinion though, others may vary, but we had this discussion with out originators and said no deal since we do not comply with E-sign in any way.

Cheers!

Agree with AFaquir.

The consent procedure is required under ESIGN for all electronic delivery. Do a search for electronic consent here on BOL and you will get a wealth of information. Richard Insley appears to be the expert in this area. Here is one such post:

http://www.bankersonline.com/technology/guru2010/gurus_tech092010b.html

We've discussed ESIGN extensively since BOL opened for business and there are scores of threads you can review. One quick way to get into them is to do an advanced search using "consent" in the Keyword Search Terms field and "Richard Insley" in the Display Name Search field. Set the search period for 10 years.