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In the section of the e-sign disclosure for Required Hardware and Software, is it okay to state “the minimum system requirements for using (name of vendor) system my change over time. The current system requirements are here:” and provide a link to the page on the vendors website that list all of the requirements? Or must we list everything that is already on that page?
Your disclosure should state the minimum requirements as opposed to a link to the vendor’s website. Having the minimum requirements listed on your site can serve as documentation that the specifications were provided at that point in time, which will help you determine if there is a change in the future that needs to be redisclosed. Putting the burden on the customer to continuously check for updates to the requirements opposed to redisclosing is not notifying the borrower of changes in software/hardware requirements as required by ESIGN.
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