Answer by Richard Insley:All your favorite laws and regulations apply in much the same way they would apply to loans originated through any other channel.
Answer by Andy Zavoina:This question could take volumes to answer accurately. As Richard noted though, your regular disclosure rules will apply. The timing of these can be an issue, depending on the products offered. As you noted, CIP will be a major issue and you need to combat fraud. This may be assisted on existing customers as you implement Multi-Factor Authentication Procedures. You still need to be concerned over E-SIGN rules for federal issues and UETA for state, if applicable.
First published on BankersOnline.com 5/15/06