How do you document receipt of appraisals prior to consummation? By use of an internal form, acknowledging receipt? Do you mail a copy of the appraisal with a dated cover letter? By e-Sign with proper consent? I'm looking to re-vamp some of our processes, as we seem to have a few inconsistencies. Thanks for the feedback!

1002.14 does not require acknowledgement for receipt of the appraisal by the applicant.

We simply mark the file whether the appraisal was provided in person, by mail or electronically and the date it was provided.

Does the consumer need to provide consent through E-Sign to receive the appraisal? We're not talking about any disclosures, simply to say, "go ahead and email the appraisal"?

(5) Copies in electronic form. The copies required by § 1002.14(a)(1) 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.).

Yes, the consumer would need to provide the proper E-Sign consent for you to deliver the appraisal electronically. Otherwise, based on the citation Randy gave, it would be like you never sent the appraisal at all - which, of course, would be a big problem.

Keep in mind that E-Sign is much more than simply saying "go ahead and email the appraisal". E-sign requires things like disclosures, a reasonable demonstration they will be able to access the documents electronically, and consent. This FDIC document outlines the required steps for E-Sign in more detail here: https://www.fdic.gov/resources/supe...xamination-manual/documents/10/x-3-1.pdf