The CFPB wants to learn about the electronic closing business and is looking for agents who currently have some electronic closing system in place. They are the government and they are here to help the consumer. The CFPB's vision is for a "knowledgeable, empowered homebuyer experiencing a more efficient, consumer-friendly process." If you do eClosings, Read on….
The minimum functionality levels to be included in the pilot are:
1. Managing document and data transfer
Secure document storage and transfer between lender, consumer, settlement agent, and downstream investors.
2. Secure technology platform enabling transparent, collaborative workflow
Pilot participant must have a central repository for all closing documents and allows for the various stakeholders not only to view documents, but also to interact with them.
3. Facilitating electronic signatures
Must accept ESIGN and UETA1 electronic signatures from the borrower on the closing documents. Hybrid process where some wet signatures are requires is allowed.
4. Ability to audit
Auditing of sending, viewing, signing with tamper-evident seals on signed documents. Ensure a single version of the document is readily identifiable and not duplicable.
5. Ability to sanitize data
Strip, mask, or otherwise minimize access to sensitive data fields not necessary for analysis, including specific types of PII.
To make a proposal some additional criteria is needed.
Data Samples - 3 month estimate of eClosings with breakdown of purchase versus refinance transactions.
Consumer Awareness Methodology - Marketing Material, how your process is expected to increase consumer awareness of the loan process.
The unedited story is at http://files.consumerfinance.gov/f/201404_cfpb_guidelines_eclosing-pilot.pdf