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#2251615 - 03/31/21 06:42 PM DOD Disclosure - Signature Requierment
It's not easy Offline
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I'm not seeing a requirement to have the borrower sign the DOD written disclosure. From what I can tell it just needs to be provided in a form that they can keep. Is this correct?

Also, if anyone uses Laser Pro has anyone removed the signature requirement? Thanks!

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2251667 - 04/01/21 02:10 PM Re: DOD Disclosure - Signature Requierment It's not easy
rlcarey Online
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rlcarey
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Galveston, TX
What written disclosure?
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#2251705 - 04/01/21 07:59 PM Re: DOD Disclosure - Signature Requierment It's not easy
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Randy, I am assuming they are referring to 232.6 in the MLA.

(d) Methods of delivery—(1) Written disclosures. The creditor shall provide the information required by paragraphs (a)(1) and (3) of this section in writing in a form the covered borrower can keep.

There is no acknowledgement requirement for those disclosures.
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#2251744 - 04/02/21 03:30 PM Re: DOD Disclosure - Signature Requierment It's not easy
Andy_Z Offline
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Andy_Z
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I'm not familiar with LaserPro and agree with Dan on the possible form referenced as there isn't much else. I would urge banks to resist having a signature line where it is not required. Suddenly the bank creates a need for a signature where there is none, auditors will want it signed for completeness and the bank then has another document to retain/scan and keep for some period of time.

Instead I recommend not including an optional sig line, and ensuring that procedures are followed such that disclosures are made as required and this proves to be true in testing and interviews with applicable staff.
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#2251746 - 04/02/21 03:41 PM Re: DOD Disclosure - Signature Requierment It's not easy
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,266
Galveston, TX
I see it as no different than a CD that does not require a signature. Not sure why you would have different requirements internally for receipt documentation purposes if you require the other disclosures to be signed.
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