Our originators currently control sending documents to their applicants...their platform allows them to do that without any documented consent.
If those documents include federal disclosures that must be delivered "in writing", then you have a systemic problem that should be corrected yesterday. Manual processes are never the best choice, but in the short run, that may be all you can do.
Lenders usually have the advantage of face-to-face contact with their customers at the outset of a loan origination. That's the time & place to slip in the "paper or plastic" question and get the customer's consent. ESIGN doesn't have rigid rules about the process, so you can cover the necessary "how-it-works" explanation in conversation. Develop a script or at least a series of talking points for the lenders. After they give the customer the standard explanation (including the need for a "test drive") they could get the customer to sign a paper consent form if that fits in with your overall process. Note that the paper form is symbolic--nothing is official until the customer gives consent or confirms consent electronically
(in case you used a paper form during the interview).
Assuming you're sending PDF attachments to email messages, you need to develop a simple pdf form for the test drive. You're free to include anything, but it's a good idea to list all of the ESIGN preconsent disclosures--even if you already covered them during the interview. The purpose of this test document is two-fold. First, it will demonstrate the customer's ability to receive, open, and read the content of e-documents of the type your lenders will use for subsequent messages--including federal disclosure forms. Second, the document can include a two-click consent mechanism that satisfies ESIGN.
To turn the test document into an action item, add a link to a stand-alone page on your website. When the customer clicks this link in the test pdf document, his/her browser opens and up pops your "E-delivery Consent" page. This page contains a simple form that says something like "Enter your email address here [(data entry field)] and click [this button] to confirm your consent to the use of electronic documents during the processing of your loan." That's it for the customer. Behind the scenes, when the customer clicks the consent button, that triggers a program that can do anything you want. At a minimum, it should add the customer's email address to your file listing customers who have opted in for e-delivery of loan processing documents. It's also good practice to save a timestamp and log the customer's IP address. If possible, you'll want to make the program generate an email message or other notification to the lender. That message will serve as the green light to proceed with e-delivery. As a courtesy, you might want to CC the borrower.