Compliance Alliance Question of the Week

Question:
Why do we have to have two copies signed at closing for the notice of right to rescind?
 
Answer:
The regulation requires that two copies of the notice of right to rescind be delivered to each consumer entitled to rescind, but there’s not a regulatory requirement that the copies be signed. The signature requirement may come from bank policy to document that the consumers received the notices, but the signatures aren’t required by Reg. Z.
 
(1) Notice of right to rescind. In a transaction subject to rescission, a creditor shall deliver two copies of the notice of the right to rescind to each consumer entitled to rescind (one copy to each if the notice is delivered in electronic form in accordance with the consumer consent and other applicable provisions of the E-Sign Act).
1026.23(b)(1), https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1026/23/#b