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#1890242 - 01/24/14 07:48 PM Privacy Disclosure
deh Offline
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Joined: Mar 2006
Posts: 866
We just switched to a new Loan Operations Sys. We are having issues with the fact that we used have forms with signature and date lines and now we do not. One of the forms is our Privacy notice which we always used to have a copy of the signed and dated one in the loan file for examiners review.

Do you think they would accept a blank copy in the file if we image our loan files? Or do you think we need to make sure the borrower signs and date these forms even though there is no signature date line? Please advise!

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#1890299 - 01/24/14 08:43 PM Re: Privacy Disclosure deh
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Why don't you just document delivery in the cover letter with all of your other early disclosures, of which none require signatures?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1890378 - 01/24/14 10:03 PM Re: Privacy Disclosure deh
deh Offline
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Joined: Mar 2006
Posts: 866
We don't do a cover a letter. However, I suppose we could....

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#1890439 - 01/25/14 12:17 AM Re: Privacy Disclosure deh
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You do not need all of those signatuures. Why set yourself up for "errors"?
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1891166 - 01/28/14 04:50 PM Re: Privacy Disclosure deh
deh Offline
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Joined: Mar 2006
Posts: 866
How do you document the file that you provided the disclsure?

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#1891234 - 01/28/14 06:22 PM Re: Privacy Disclosure deh
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If you are mailing the disclosures, you say dear applicant, attached you will find the following disclosures in relation to your recent mortgage application:

GFE
early TIL
Privacy disclosure
etc., etc.,etc.

You put a copy of the cover letter in file.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1891453 - 01/28/14 10:18 PM Re: Privacy Disclosure deh
deh Offline
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Joined: Mar 2006
Posts: 866
Gotcha, I wasn't sure that was what Kathleen B meant as well.

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