What is the best way to document that an appraisal was received by a customer? Should we require a signature? I was thinking since sometimes they would be mailed and sometimes e-mailed requiring a signature might not be best. I was thinking of having a form the loan officer had to fill out and sign saying when it was delivered…..
If your procedures show that you are complying with the requirements and your file is documented with the delivery date I believe that is sufficient – a signature isn’t required and, I agree, may be difficult to always obtain. The commentaries to Reg B and Z note that provide or deliver is deemed to be 3 business days after the appraisal/valuation is mailed or when there is evidence of actual receipt (for email consider e-sign). So, if you have documented when the appraisal was sent should be sufficient documentation to show compliance. A formalized and consistent process for documenting delivery would be a sound addition to your procedures.
Would a commercial loan subject to reg B, but not reg Z fall under e-sign rules for this disclosure?
Also, what is the best way to document e-sign through e-mail? We are set up on our website for e-sign disclosures when someone signs up for e-statements, but I am not sure how this would be done via e-mail? Would an e-sign document at application that the customer signs in person be acceptable relating to future documents (such as this one) involved in the transaction?