I'm just getting my feet wet in lending compliance and I have the following question. Does there need to be a copy of the "initial program disclosure" placed in the loan file to document compliance? If so, should it be signed by the borrowers? I'm assuming we just hand out the "When your home is on the line..." brochure at application and won't have way to prove compliance with that requirement.

There is no regulatory requirement to have a copy of the plan disclosure in the file nor have it signed by the applicants.

You have to document your process in how you provide the disclosures and demonstrate that process works.

We use application packets that have all the required disclosures for the specific product.

Thanks for the quick response Dan!

Dan's advice is very good. You reduce risk by strengthening systems in favor of getting signatures on everything.