Answer by Richard Insley
Yes. Following ESIGN's disclosure and opt-in scheme, RESPA disclosures can be given electronically. HUD is free to issue "how to" regulations (as the FRB has done) to supplement ESIGN, but you've had the authority to deliver electronic RESPA disclosures since 10/1/2000.
Answer by Andy Zavoina
If compliance officers held their breath waiting for HUD interpretations the lobbies would be littered with their bodies.
Don't depend so much on HUD now as the e-Sign legislation that allows electronic disclosure under certain circumstances. Your customer has to agree to them and meet other qualifications as do you. The bank still has to meet the regulatory timing requirements and ensure that certain disclosures are provided before other steps in an application and loan process take place.
First published on BankersOnline.com 5/7/01