We are changing our LOS, and the new version does not provide separate forms for borrower 1 and 2 to sign as they sign the TILA/TRID CD. They are provided 2 copies for each borrower, however, to take with them, as prescribed by 1026.15(b). I have worked with probably 5 LOS systems through my career, and have only seen where each individual signs their own separate disclosure at the closing table, and leaves with 2 copies. I am not seeing in Reg Z or it's commentary where multiple borrowers cannot sign the receipt of form disclosure on the same document. Has anyone else run into this? Have there been any comments from either auditors or regulators?

Considering that is no requirement for a signature on the form to evidence receipt, you are not going to find much guidance in the regulation. If you sell on the secondary market, that is going to be you biggest concern - i.e., meeting investor requirements.

Thanks much - As bankers, we get entrenched in "that's the way we have always done it, so it must be right" mentality. This one gave me pause to think. We should be OK, given we sell no loans on the secondary market.

I've never seen an ROR that only has one borrower name on it.
All of ours have had the names of all borrowers who receive the ROR on every copy and that's over 3 or 4 different LOS we've used.
As Randy said, there's no requirement for sigs but investors use one to document proper delivery just like they want LEs and CDs signed and dated.
So whatever your system gives you should be good.

I've never seen an ROR that only has one borrower name on it.

I don't think that is what Moma is saying.

Our system generates a ROR form with both names on it and 5 copies. 2 for each borrower to take with them and our file copy.

I think Moman is use to seeing separate copies for each consumer with the ROR so he is used to seeing 3 copies for each consumer with rescission rights.

Dan - you are spot-on. I am used to seeing each borrower getting a copy to sign at closing + 2 to take away for a total of 6 for 2 borrowers. Providing the borrowers do not rescind, there would be 2 signed copies in the loan file for review. In the case of our new LOS, there will only be 1 copy in the file with each person's signature on the same single copy.

As long as each borrower is getting two copies - what the bank retains as documentation in not a regulatory issue. One or two copies with signatures is just bank documentation.