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#2138099 - 07/14/17 10:23 AM email notice
Burgess Offline
Diamond Poster

Registered: 01/27/04
Posts: 1499
just checking myself.
I have said that while it is ok to email the appraisal notice...it has to be done esign compliant.
agree?
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My views, not my employer's views.

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2138109 - 07/14/17 10:38 AM Re: email notice [Re: Burgess]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 64016
Loc: Galveston, TX
Yes, unless provide with an electronic application form:

1002.4(d)(2) Disclosures in electronic form. The disclosures required by this part that are required to be given in writing may be provided to the applicant in electronic form, subject to compliance with the consumer consent and other applicable provisions of the Electronic Signatures in Global and National Commerce Act (E-Sign Act) (15 U.S.C. 7001 et seq.). Where the disclosures under ยงยง 1002.5(b)(1), 1002.5(b)(2), 1002.5(d)(1), 1002.5(d)(2), 1002.13, and 1002.14(a)(2) accompany an application accessed by the applicant in electronic form, these disclosures may be provided to the applicant in electronic form on or with the application form, without regard to the consumer consent or other provisions of the E-Sign Act.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2140518 - 08/02/17 03:01 PM Re: email notice [Re: Burgess]
Likes to Comply Offline
Platinum Poster

Registered: 11/07/08
Posts: 608
Loc: In the mountains
We provide the appraisal disclosure with the application. If the application with appraisal disclosure is emailed to the applicant, would E-Sign still be applicable? While not accessing it from our website, they are still accessing the application with appraisal notice in an online, electronic manner...
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#2140796 - 08/04/17 10:36 AM Re: email notice [Re: Burgess]
John Burnett Offline

10K Club

Registered: 10/27/00
Posts: 36288
Loc: Cape Cod
E-SIGN would not be applicable in that situation, Likes to Comply.
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John S Burnett
BankersOnline.com
Professional Compliance Nerd since 1976.

"Illegitimi non carborundum"

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