Pub. 9 2019-2020 Issue 6

14 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S — H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S www.coloradobankers.org E-SIGN Considerations in Mortgage Lending — From Application to Consummation BY CINDY PRINCE Online account opening, particularly for mortgage loans, is one area that continues to grow. At first, banks were just using electronic banking as a way to deliver disclosures faster, but these days, more and more banks are taking applications, delivering disclosures, and closing loans all online and without ever seeing the borrowers. This being the case, let’s take a look at each step of the process and what the bank must do to stay compliant, from application to consummation. We’ll start by providing mortgage applicants with the application form. There are a few regulations that come into play here. Regulation B allows you to provide an online applicationwithout first obtainingconsent toreceivedocuments electronically. Keep in mind that if you are providing an online application for a home-equity line of credit (HELOC), you must also provide the initial HELOC disclosure and HELOC brochure (When Your Home is on the Line) at application, as required by Regulation Z 1026.40(d) and (e). I n the fast-paced world we live in today, everybody wants things done as quickly and conveniently as possible. People are so busy that having to take time to come in to the bank to conduct their business seems like an imposition. We have made it so easy for our customers that, inmany cases, they neverhave tostepfoot intothebank.