With mortgage rates at historic lows, many credit unions are seeing an increase in mortgage application volume and credit unions are looking for ways to speed up their processing times. Some credit unions attempt to decrease their mortgage turn times by going digital, as discussed in a blogs regarding online applications and electronic signatures. Other credit unions try to make the process easier by determining which of the many disclosures must be signed, and if those signatures must be obtained upfront or can be done throughout the process or at the signing table.
Many of the mortgage disclosures provided to the member do not have a federal regulatory requirement for a signature. Rather, the regulations require that the credit union provide the disclosure, so in many cases it may be sufficient for the credit union to have procedures and documentation showing that the disclosure was sent. Even if there is no regulatory requirement for a signature, there could be secondary market considerations (such as if the credit union sells loans to Fannie Mae/Freddie Mac or other purchasers) as well as possible state law requirements.
Borrower’s Verification Authorization
None, because this is not a federally required disclosure. However, this disclosure may fulfill a third-party’s requirement to have signed consent to share information with the credit union.
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