This is the scenario. Borrowers sign the privacy policy disclosure at time of application, indicating that they want to opt out and sign the disclosure. The same disclosure is sent to closing, and the borrowers sign the disclosure, but do not check the opt out boxes. Which disclosure do we use?

Please advise! Thanks!

I would err on the side of caution and unless I specifically had something in writing that stated that the customer was opting back in - I would put them on the opt out list. I would ignore the fact that they failed to check the appropriate boxes the second time around. I would also review your processes and eliminate this duplicate effort.

Thanks Ron! You gave me the ammunition I needed to address the duplication factor. I questioned this when the question was posed to me by the processors.

Have a great day!