6721 Electronic signature date stamp shows loan out of compliance

Issue

The electronic signature date stamp for documents sent through Zip or WebCaster indicates the loan is out of compliance when the documents were signed before the time period expired.

Cause

Ink-it date and time stamps are based on Coordinated Universal Time (UTC), also referred to as Greenwich Mean Time (GMT), and the documents were signed after midnight at that time, not necessarily the user’s local time.

Because the company that processes our document signing packages is bound by regulations to use a centralized time for all transactions, the signature time and date stamps are based on Coordinated Universal Time, not your local time. Therefore, even if the package is signed within the signing deadline, if it was signed after midnight UTC on the day of the signing deadline, the date stamp will indicate the document was signed on the next day.

In the following example, the Audit Trail shows that the borrower, Jonathan Smith, started signing his documents on May 22 at 18:10 (6:10 p.m.) GMT (10:10 a.m. PST) and completed signing at 18:11 GMT (10:11 a.m. PST).

The co-borrower on the loan, Jane Smith, didn’t sign the documents until later that day, approximately 5:40 p.m. her local time (PST), as shown in the following example. However, because she signed the documents after midnight UTC, her signature was stamped as occurring on the next day, May 23, which was a day past the signing deadline.

This scenario can cause confusion among auditors who then flag the loan as out of compliance when it actually is not.

Resolution

To avoid this potential compliance issue, keep the following in mind when packaging documents for electronic signature:

• If possible, send document signing packages a day or two before the signing deadline.
• If that is not possible, send document signing packages early in the day on the last signing day and encourage individuals in the signing party to sign their documents as quickly as possible.

If you find that you must demonstrate to the auditor that the loan was actually signed before the deadline and is in compliance, use a time converter (easily located by searching a browser) to illustrate the difference between Coordinated Universal Time (or GMT as used on the audit trail) and your local time.

Coordinated Universal Time (UTC) is used as the reference for all time zones in the world. UTC time is expressed as UTC +0000. Local time throughout the world is expressed as UTC ±0n00, where n equals the offset. The offset will change depending on your time zone. For example, the offset for Pacific Standard Time is -8 so it is expressed as UTC -0800. Therefore, if the time is 10:00 p.m. in a zone where the UTC offset is +0000, the time in the Pacific Standard Time zone is 2:00 p.m.

The following table shows the UTC offset for time zones in the United States during standard time:

*The offset for daylight savings time is one hour less where observed.