In search for further guidance on compliance for delivery of a Closing Disclosure (CD) by way of email (with a borrower's E-Sign consent) we have varying differences in the interpretation of the word "Receipt".
It has been our department's practice to deliver the CD within no less than 3-business days prior to closing. Documentation to evidence delivery has been by including a printed copy of 1) email showing our department's delivery of the CD to the borrower by way of email, and/or 2) a printout showing the "Arrival Date" of the email/attachments to the borrower.
Some have interpreted the "Receipt" rule as evidence the email and attachment(s) was "OPENED". Are we in violation if a loan is scheduled to close on a Monday and the borrower did not “OPEN” the email until the 2nd business day (Thursday) prior to closing – even though we have evidence to show “ARRIVAL” of our CD on or before the 3rd business day prior to closing?
Imaging software is expensive, but is it worth it?
We are now scanning all of our deposit and loan documents for our customers. Is there any reason to "block" our lenders from viewing all the documents - such as a drivers license? Currently our lenders are blocked from viewing all deposit documents as well as CIF documents - signature cards, resolutions, trusts, drivers license, etc. Our lenders are required to capture the information from the drivers license when completing the loan application. I can remember back when we had loan files that we weren't allowed to keep a copy of the DL in the file. But now that they are scanned, do they need to be "blocked" from certain employees for viewing?
Reg B - appraisals - can we email a copy of the appraisal to the Borrowers as long as it is secured and we get a read receipt for the email? How long after this do we need to wait to close the loan?
Should we stick with the status quo or go paperless?
Should banks use iPads or tablet devices to streamline loan management?