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The signature line on the Loan Estimate and Closing Disclosure for a mortgage loan is optional under Regulation Z but may the bank require a signature?

I know that under Regulation Z the signature line on the Loan Estimate and Closing Disclosure for a mortgage loan is optional. May the bank require a signature?

Yes, but with a caveat. As long as the consumer has the ability to retain a copy of the disclosure(s), the bank may require a signature. The Consumer Financial Protection Bureau recently updated its TILA-RESPA Integrated Disclosure FAQs with a FAQ that answers this question.

A creditor may include the signature line and require the consumer to sign the disclosure, but only if the consumer receives the disclosure in a form that they may keep. . . The consumer must have the ability to retain a copy of the disclosure after returning the signed disclosure to the creditor.

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(July 2020)

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