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?