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E-Sign & Commercial 1st lien dwelling secured

Home Forums Equal Credit Opportunity Act/Regulation B E-Sign & Commercial 1st lien dwelling secured

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  • #4065
    TheBank
    Participant

    Since the Reg B rule to provide a copy of the appraisal on a 1st lien dwelling secured commercial purpose loan will be applicable to non consumer purpose loans, will those loans be subject to E-sign when providing the appraisal electronically? We are looking at providing appraisals electronically since they must be provided promptly upon completion/3 days prior to closing unless the timing can be waived but need to implement an E-sign disclosure, demonstrative consent, etc… E-sign Act reads as if it only applies to consumers, but thought I should double check that. For commercial purpose loans, would we have to comply with E-sign to provide those appraials electronically?

    #4066
    rcooper
    Keymaster

    Yes, for electronic delivery, you must obtain the applicant’s consent under the Electronic Signatures in Global and National Commerce Act (E-Sign Act). You will find information about E-Sign at https://www.fdic.gov/regulations/compliance/manual/pdf/X-3.1.pdf.

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