Basically yes. Delivering the app electronically isn't the collection of any information.
Some, or perhaps many, of the disclosures that you may want to make in response to that application that are required to be "in writing" would require E-SIGN acceptance.
Documents that do not have to be in writing wouldn't and some exemptions from E-SIGN disclosures do exist. Again, most triggered disclosures would not fall in this category.
You can deliver your disclosures in typical written form. One issue to watch with the delivery of applications, such as for an ARM, require disclosures to accompany the application.
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AndyZ CRCM
My opinions are not necessarily my employers.
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