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#2175814 - 04/30/18 02:36 PM Loan Estimates
Mike T Offline
Member
Joined: Dec 2016
Posts: 74
getting a pushback from the investor. We use Point software for a LOX. We have doc magic for disclosures.
The loan officer sent a revised LE via Point which was signed. The investor stated the initial disclosures were sent through Doc magic thus all disclosures have to be sent via Doc magic. I don't see it anywhere in the regz regarding this notation.

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TRID - TILA/RESPA Integrated Disclosures Rule
#2175817 - 04/30/18 02:44 PM Re: Loan Estimates Mike T
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,417
Galveston, TX
Investors make their own rules. Can you deliver paper docs after a customer agrees to electronic documents - sure, there is no such prohibitions in the regulations or law.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2175830 - 04/30/18 04:06 PM Re: Loan Estimates Mike T
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,535
Bloomington, IN
I'm not sure if they are referring to E-sign delivery.

If my original disclosures were generated by one software (Doc Magic in this case) then I would want all subsequent disclosures generated by the same software (Doc Magic) for tracking and consistency in the disclosures. How can I be certain Point appropriately tracked the difference between figures entered into Doc Magic for the disclosures vs. those generated by Point. Intermingling disclosures between separate software programs is never a good idea.

I understand Point most likely feeds Doc Magic but if Point generated the revised disclosure then that would indicate to me those updated figures were not fed into Doc Magic.

As Randy stated it's not a regulatory requirement but it would be one I would put in place as an internal requirement.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2175849 - 04/30/18 05:07 PM Re: Loan Estimates Mike T
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,417
Galveston, TX
Happens all the time and we don't see any problem with secondary market investors. People generate their own LEs from their own system and then order the loan packages and closing disclosures through us all the time.

However, I see what they might be are saying now. If they got their E-Sign agreement through DocMagic and didn't get another E-Sign agreement through Point, then agreeing to acceptance in one system is not a universal acceptance for multiple system deliveries depending on how the agreement may be worded.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2176063 - 05/01/18 03:54 PM Re: Loan Estimates Mike T
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
Yes, that is what may be going on. Just because the applicant proved they can access the document through Point, does not necessarily mean they can access the document through DocMagic. But, if this is what the issue is, then you could also technically just have the applicant express consent again through the DocMagic process.

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