[sbs1]

We are using an in house digital system and they do not want underwriters to have to scan in extra documents, etc. If the closing disclosure is given to a customer in person, and the loan officer types in the date on a mailing/delivery spread sheet that we have in each file, is just that date entered sufficient to prove delivery or should the loan officer document the file in more detail.

[rcooper]

There isn’t a requirement to have the CD signed nor are there required procedures for documenting delivery, you just have to show evidence of compliance. I would consider if you feel it provides evidence of delivery in a timely manner, can it be applied consistently, is the spreadsheet documented as the actions are taken and does it show accountability of the person providing the documents/inputting the dates, and if there are investors involved are you meeting their standards? Personally, I would prefer to see some type of additional documentation that it was delivered or received either from the loan officer or the borrower, but it isn’t necessarily required.

Since this sounds like a big procedural change, potentially affecting numerous disclosures, you should consider consulting with your auditors or examiners to see what they expect and how they will view your process since they will ultimately be the ones reviewing the files.

[Author]

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