Can the Military Lending Act Statement be provided electronically?
The Regulation does not address providing disclosures electronically. This omission could be interpreted to mean that as long as you provide the disclosure in writing and in a form a covered borrower can keep (even if electronically), this is sufficient. In our opinion, we would recommend following E-SIGN requirements, especially since you will need to do so under Regulation Z anyway.
Join us for the Military Lending Act Webinar on August 22, 2019. We will answer all the questions submitted during the live webinar, in writing.