Though we do require customers to sign Good Faith Estimates/Service Provider Disclosures, initial Truth-In-Lending disclosures and Mortgage Servicing Disclosures to acknowledge receipt, only the Mortgage Servicing Disclosure acknowledgement is required prior to settlement. We're thinking about eliminating the bank's requirement for signatures on the Good Faith and T-I-L forms, but we also need to show that they were provided to the applicant(s) within three business days of application.

I would appreciate knowing what other banks are doing. Do you require the signatures on all disclosures? If not, how do you document the timely delivery of the disclosures?

Thanks.

We get signatures on GFEs and TILs only if they are prepared and given during the taking of a face-to-face application. Otherwise we mail them within 3 days and the employee doing the mailing writes "mailed mm/dd/yy" on the signature line and signs or initials it.

It is a good idea to document your loan compliance process with a checklist. I generally have clients check off the compliance requirements with a data and initials of the person who did it. This serves as a reminder for the compliance requirement and as a form of proof that the disclosure was sent.

Another method is to have a loan packet assembly procedure or checklist. It would also function as proof of a procedure and create a presumption that the disclosures were sent.