We are involved indirect lending and have some dealerships who are wanting to move in the direction of getting documents signed electronically (for example: in situations where the car is delivered to the customer at home, and they never actually step foot in the dealership any more, so borrower would e-sign from their home/phone etc.). Bank would have a audit trail providing an IP address, but it wouldn't provide a location where the signature was provided). Are there compliance concerns/issues with this? or is this more of a legal/agreement type concern/issue? We plan to discuss with our legal counsel, but also wondered about any compliance concerns or issues. Thanks.

Outside of making sure that the dealer is complying with E-Sign for disclosure delivery, I would be relying on my legal counsel regarding the E-Signature issue.