We are doing a loan subject to TRID and this loan is a joint loan. What happened is that the primary applicant went in and consented to the e-sign on the date of application, however the co-borrower/joint applicant did not do so until well after the 3 day requirement. From what I have found for the LE is that as long as the primary borrower has consented we are ok, however what about all of our other early disclosure documents does the same apply to these?
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.