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Our website has a modified application. Prior to the customer opening the application, the disclosures for ARMs, HELOCs, along with the appropriate booklets are available through links on the page. The customer must check that they have read the disclosures to go to the application.
The question is: Is this adequate for the required “at application” disclosures? Is it compliant with the eSign Act?
How are other banks handling “at application” disclosures for online mortgage applications?
Here’s a link to the E-SIGN Act: https://www.gpo.gov/fdsys/pkg/PLAW-106publ229/pdf/PLAW-106publ229.pdf. Take a look at 101(c).
Generally, you need to provide notice of rights and certain inforamtion prior to consent, provide information on hard/software prior to consent, and document consent to obtain the documents in an electronic format and demonstrate that the consumer can receive/obtain the documents in the format you will use.
Maybe others will weigh in on how they accomplish this:)
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