Has anyone gone through the compliance requirements for E-Signatures for Bank of America short sales? If so, do you have any quick tips? Specifically for:

• Certification of Completion • And/or Audit Trail

Here is part of the requirement, what is your opinion and experience?

– Bank of America now accepts electronic signatures on some
documents collected during the short sale process. The change has
been made in response to feedback we have received from real
estate professionals.
• Each real estate partner or agent is responsible for selecting its own thirdparty service provider (i.e., e-sign vendor) to present electronic
documents and capture electronic signatures on its e-signing platform.
• *****************Each agent must perform its own due diligence on an e-sign vendor and
its e-signing platform to, among other things, ensure the e-signing
platform’s ability to comply with the various Bank of America
requirements set out below.
• ****************Each agent must enter into its own contract with its selected e-sign
vendor that, among other things, obligates the e-sign vendor to comply
with the bank’s requirements.
– Those requirements are set out below and on the Bank of America Real Estate
Agent E–Transaction Terms of Service Disclosure.
• *********************All costs, expenses and risks associated with an agent’s use of its chosen
e-signing platform are borne by the agent, not Bank of America.

SKIPPING TO THIS SECTION:

Disclosure, Audit & Integrity Requirements for E-Signed Transactions 

– The signing platform must generate and provide to the user/signer:
• The Bank-provided E-Transaction Consent Disclosure, also prior to his or her receipt of
any document on the e-signing platform (except for the vendor disclosures).
– Disclosure must be printable and retainable; user/signer must be encouraged to do so.
– The e-signing platform must then also obtain user/signer consent to obtain
documents electronically and agreement to use electronic signatures on any
documents presented.
• Consent must be obtained on e-signing platform from each user/signer in a manner
that reasonably demonstrates his or her ability to receive electronic documents.
– The e-signing platform must then generate and provide to each user/signer:
• A printable/retainable copy of:
– All documents presented on the e-signing platform, including those that are electronically
signed.
– A tamper-sealed certificate of completion, transaction log or other e-signing platform audit
trail (audit log) when the entire signing transaction is completed by all user/signers.
Electronic Signatures Reference Guide

• An IP address on all activity related to each e-signature transaction
(including document level audit detail).
• A Globally Unique Identifier (GUID) or transaction identification number
that is:
– Associated with each user/signer and document at the time of authentication
and signature creation.
• A hash of any digital signature by means of which the e-signing platform
tamper-seals each document.
– Any change in the underlying document would produce a different hash value
when subsequently validated on the signing platform, which would then be
evidence of tampering.
• A visible e-sign vendor stamp or electronic signature on the document to
indicate the e-sign vendor that made the e-signing platform available.

ETC ETC ETC ETC ETC