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#2219012 - 08/02/19 04:11 PM Fiber Optic Line Cut unable to produce an LE?
ccman Offline
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Joined: Sep 2007
Posts: 937
We recently experienced a loss of internet connectivity at our OPs offices and unable to produce an LE for an applicant?
A fiber optic line was severed on our street due to construction by the city and disconnected all internet connectivity to most
of the southeast side of the city. The repairs took 2 1/2 days with six repair trucks to finally get the repairs done.

Our lender in another city received an application on Monday for a Construction Loan. The loss connectivity
occurred on Tuesday afternoon and was not repaired until Thursday morning (9am). The applicant info was not sent to Ops Center
until Thursday after the offices had closed. Can the LE be prepared and sent to the applicant on FRIDAY without being considered a
VIOLATION??

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TRID - TILA/RESPA Integrated Disclosures Rule
#2219021 - 08/02/19 04:40 PM Re: Fiber Optic Line Cut unable to produce an LE? ccman
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
My only question is where the heck was your business continuity/disaster plan during this whole thing? In other words - there is no provision for missing a deadline in the regulations.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2219024 - 08/02/19 04:47 PM Re: Fiber Optic Line Cut unable to produce an LE? rlcarey
ccman Offline
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Joined: Sep 2007
Posts: 937
Well that was my question at the beginning with IT. Their reply was that since the fiber optic line was cut, there is no way to reestablish a
connection to the internet without having another ISP line available that the remote Disaster Recovery Site could communicate.

IT is now looking at establishing another ISP with multiple lines of connectivity that the recovery site can communicate with in the event of
just such events, disaster, etc.

Thanks for your reply.

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#2219025 - 08/02/19 04:50 PM Re: Fiber Optic Line Cut unable to produce an LE? ccman
Kimo in Idaho Offline
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Joined: Jun 2019
Posts: 135
I agree with carey. You do have a violation of the regulation and your BCP should be built to handle this type of issue. Now you have multiple issues that examiners will raise both individual loan(s) and the BCP question and hopefully you can show what you have done to handle this in the future.

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#2219026 - 08/02/19 04:51 PM Re: Fiber Optic Line Cut unable to produce an LE? ccman
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
It doesn't sound like much of a disaster recovery plan if something that takes out your current location impedes you from operating out of your remote site. Sorry, that makes absolutely no sense to me.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2219028 - 08/02/19 04:56 PM Re: Fiber Optic Line Cut unable to produce an LE? ccman
Kimo in Idaho Offline
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Joined: Jun 2019
Posts: 135
Again I agree, you had better have a better answer before the examiners are in your office.

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#2219036 - 08/02/19 05:22 PM Re: Fiber Optic Line Cut unable to produce an LE? Kimo in Idaho
ccman Offline
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Joined: Sep 2007
Posts: 937
Hold on guys! I am told that this was not the case at all. Appears to be a case of human error and not wholly related to the failure.

Thanks for the concern.

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#2219054 - 08/02/19 06:41 PM Re: Fiber Optic Line Cut unable to produce an LE? ccman
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,400
I thought a basic disaster plan had to include the ability to produce an LE without any electronic input.
You know, pen and ink and calculating APR by hand.

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#2219059 - 08/02/19 06:53 PM Re: Fiber Optic Line Cut unable to produce an LE? Truffle Royale
ccman Offline
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Joined: Sep 2007
Posts: 937
Same here!

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