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#456847 - 11/15/05 03:19 PM Disclosures on website
Gina Z Offline
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Joined: Nov 2005
Posts: 6
Our bank's website allows customers to apply on line for home equity loans, personal loans, home equity lines of credit. Which disclosures are required to be on the website before or with the online application?

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eBanking / Technology
#456848 - 11/15/05 09:00 PM Re: Disclosures on website
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,627
The Swamp
You probably need to review the e-sign act and 226.36 (reg z)

Here's a good place to start on esign info.
Last edited by joker; 11/15/05 09:05 PM.
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#456849 - 11/16/05 01:41 AM Re: Disclosures on website
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,140
On the Net
Jokers advice is good. Look at what you do in person, look at Reg. Z and RESPA, plus any state requirements which may be applicable, and look at how that would have to delivered electronically if it is required at the time of the app. If it is required within a given period, are you snail mailing it or delivering it in e-form? What E-Sign or UETA rules would apply to these?

A) You have lots of work to review here.
B) What process was used to approve what is being done? (Depending on the answer, go to C)
C) Consider taking it down until you have reviewed A above and completed an audit of what you have, do and what your risks are.
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