[TheBank]

Since the Reg B rule to provide a copy of the appraisal on a 1st lien dwelling secured commercial purpose loan will be applicable to non consumer purpose loans, will those loans be subject to E-sign when providing the appraisal electronically? We are looking at providing appraisals electronically since they must be provided promptly upon completion/3 days prior to closing unless the timing can be waived but need to implement an E-sign disclosure, demonstrative consent, etc… E-sign Act reads as if it only applies to consumers, but thought I should double check that. For commercial purpose loans, would we have to comply with E-sign to provide those appraials electronically?

[rcooper]

Yes, for electronic delivery, you must obtain the applicant’s consent under the Electronic Signatures in Global and National Commerce Act (E-Sign Act). You will find information about E-Sign at https://www.fdic.gov/regulations/compliance/manual/pdf/X-3.1.pdf.

[Author]

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