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#1967356 - 10/06/14 09:37 PM e-sign when is appraisal considered received
Baker Offline
Platinum Poster
Joined: Nov 2005
Posts: 772
Washington State
If we provide the appraisal through an e-sign tool when it is considered received? I.e. when it is made available or when customer actually opens, or 3 business days from when made available?

I asked the CFPB and they said it would be treated the same as physically mailed items. Is that correct?

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1967359 - 10/06/14 09:40 PM Re: e-sign when is appraisal considered received Baker
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 76,979
Galveston, TX
4. Timing. Section 1002.14(a)(1) requires that the creditor "provide" copies of appraisals and other written valuations to the applicant "promptly upon completion," or no later than three business days before consummation (for closed-end credit) or account opening (for open-end credit), whichever is earlier.

i. For purposes of this timing requirement, "provide" means "deliver." Delivery occurs three business days after mailing or delivering the copies to the last-known address of the applicant, or when evidence indicates actual receipt by the applicant, whichever is earlier. Delivery to or actual receipt by the applicant by electronic means must comply with the E-Sign Act, as provided for in 1002.14(a)(5).
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#1967400 - 10/07/14 11:16 AM Re: e-sign when is appraisal considered received Baker
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,296
Cape Cod
You have to build in a three-day delivery time unless you provide the copy in person. If you receive evidence of receipt sooner than three days after mailing or sending (any form of delivery other than in person), you can rely on the date on the receipt.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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