Reply To: e-sign

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I was wondering if it was an ARM because of the CHARM booklet being delivered electronically, but that shouldn’t be an issue as long as you provide it with the application. Generally for most disclosures it is acceptable to provide to the primary applicant. I can’t think of where this would be an issue for early disclosures. It would be an issue for the CD in a rescindable transaction. Also, the FCRA RBP or exception notice is require to be provided to each consumer but your probably aren’t giving that out with early disclosures.