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#1210991 - 07/01/09 09:11 PM Emailing early disclosures
Compliance Chick Offline
100 Club
Joined: Oct 2004
Posts: 192
New Orleans, La.
In my research I have found the following link to a Subpart F to Regulation Z that discusses electonic communication for Regulation Z disclsoures. http://law.justia.com/us/cfr/title12/12-3.0.1.1.7.6.8.1.html
When I read this, it makes me think that the current procedure of our mortgage division using elliemae to send earlies to applciants is ok. Loan officers create earlies within Encompass and send them electronically to applciants. Applicants get an email directing them to a website. They then create a user account with an ID and password where they can retrieve the disclsoures 24/7 for 90 days. This sounds like this Subpart F.

I even see mention to section 226.36 and Subpart F in the FDIC's Compliance Handbook. HOWEVER, when I look for Subpart F in the regualtion part of the FDIC website or federalreserve.gov, I don't see Subpart F.

What happend to it?

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Lending Compliance
#1212336 - 07/03/09 07:51 PM Re: Emailing early disclosures Compliance Chick
TheQueen Offline
Member
Joined: Jun 2006
Posts: 85
CT
I think Sybpart F describes 226.36, but it is weird that it's not part of the link in the Regulation. Anyone else have any thoughts about this?

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#1212957 - 07/06/09 05:34 PM Re: Emailing early disclosures TheQueen
elliemae Offline
Junior Member
Joined: Sep 2005
Posts: 26
By the sea ...
Subpart F and Section 36 were deleted with the final rule on electronic disclosures adopted by the Fed in 2007 (effective 10/1/08).

see: FRB Press Releases and the link to the final Reg Z rule (the deletion is in the preamble).

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