Though the ECOA Appraisal Rule isn’t new, many mortgage lenders remain unaware that they may be overlooking a key mandate within this regulation, which requires them to “obtain the applicant’s consent [to receive an electronic copy of the document] under the Electronic Signatures in Global National Commerce Act (E-Sign Act).”
Whenever appraisal files are delivered to a borrower via email, the E-Sign Act (in accordance with ECOA) requires their consent to receive said documents electronically. The borrower must also be provided with an accurate statement of the hardware and software requirements for successful receipt of the electronic document and must agree to maintain (or have access to) an electronic device with PDF reading software so appraisal documents can be viewed and downloaded.
How EVO Mitigates ECOA:
- EVO automatically sends an Appraisal Delivery email to the borrower once the files are ready, which includes a unique security code and “Access Documents” link.
- The borrower then clicks the “Access Documents” link, enters their security code, and is presented with a special disclosure and consent agreement, which can be customized by the lender as needed.
- The borrower then reads and electronically signs the disclosure and consent agreement, which in-turn demonstrates their willingness to receive the appraisal files via email in PDF format.
- Once the disclosure and consent agreement is signed, the borrower is instantly provided with the appraisal files, which can be downloaded directly to their computer or mobile device.
An electronically signed PDF copy of their consent is then uploaded to the order for the lender’s records. Likewise, EVO also logs the dates and times the appraisal files were delivered, viewed, acknowledged, and downloaded by the borrower for future audits.
It’s that simple.
For more information on EVO, and its award-winning functionality that guarantees ECOA compliance, contact Global DMS® at firstname.lastname@example.org.