Procedurally your system requires consent prior to actual disclosure to the applicant, yes? That programmed procedure must suffice. In many ways E-SIGN is more secure and verifiable than sitting at the loan desk where I've heard, there was once a back-dated document signed. (I know, I know, not in your bank.)
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell