When setting up a customer for electronic delivery of disclosures, can we provide the E-Sign consent along with all the relevant disclosures.
No, the E-sign consent must happen before you provide any subsequent disclosures. For example, suppose you want to send the Loan Estimate electronically to an applicant. The first thing you need to do is provide all of the E-sign disclosures, obtain demonstrable electronic consent, and only after then can you send the Loan Estimate electronically. E-sign disclosures and consent need to be first, and separate from all other disclosures.
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