councillleak t1_izxuabw wrote
I work in tech Financial Services, and focus specifically on the compliance of eSigning of financial assets.
The FHLBs are a thorn in our side, because while they do generally understand the compliance of accepting eNotes of conforming residential mortgages that are registered on the MERS eRegistry, they seem to have no idea that there are similar security concerns of accepting other collateral types that have been eSigned.
For our perspective, as a technology company that has expertise in eVaulting of all different asset types including Equipment Finance, Commercial Real-Estate, and Ag loans... The FHLBs today are exposed to huge risk of not being able to perfect on the collateral pledged to them that has been eSigned without a complaint vault to hold the Authoritative Copy of the loan/lease as defined by UCC Article 9-105.
How would you recommend we approach the FHLBs to educate them on the risk of fraud, specifically double pledging and other nefarious activities, so that they can promote better lending practices as all types of lenders shift away from wet-signed assets and adopt eSignature without understanding the complexities of doing so compliantly?
ProfBU OP t1_izxvw1t wrote
FHLBs have been way late to the e-signature party. They lack any semblance of an entrepreneurial spirit. It will take a stong directive from their regulator, the FHFA, to drag them into the modern era.
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