[Anonymous]

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…..

[rcooper]

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.

[Anonymous]

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?

[Author]

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