e-sign when is appraisal considered received

Posted By: Baker

e-sign when is appraisal considered received - 10/06/14 09:37 PM

If we provide the appraisal through an e-sign tool when it is considered received? I.e. when it is made available or when customer actually opens, or 3 business days from when made available?

I asked the CFPB and they said it would be treated the same as physically mailed items. Is that correct?
Posted By: rlcarey

Re: e-sign when is appraisal considered received - 10/06/14 09:40 PM

4. Timing. Section 1002.14(a)(1) requires that the creditor "provide" copies of appraisals and other written valuations to the applicant "promptly upon completion," or no later than three business days before consummation (for closed-end credit) or account opening (for open-end credit), whichever is earlier.

i. For purposes of this timing requirement, "provide" means "deliver." Delivery occurs three business days after mailing or delivering the copies to the last-known address of the applicant, or when evidence indicates actual receipt by the applicant, whichever is earlier. Delivery to or actual receipt by the applicant by electronic means must comply with the E-Sign Act, as provided for in 1002.14(a)(5).
Posted By: John Burnett

Re: e-sign when is appraisal considered received - 10/07/14 11:16 AM

You have to build in a three-day delivery time unless you provide the copy in person. If you receive evidence of receipt sooner than three days after mailing or sending (any form of delivery other than in person), you can rely on the date on the receipt.