Reg B Appraisal Timing
Question: If we can't get the appraisal completed within 30 days of taking the application, what should we do?
Answer: The 30 days you refer to in your question probably is the timing requirement in Regulation B for making a credit decision and issuing a notice to the applicant. The trigger for that 30-day period is not the date of application, but the point at which the application is complete. In the case of a mortgage loan for which you require an appraisal, the application is not complete until the appraisal is in the application file.
Regulation B does require creditors to act without delays in compiling all the information needed to complete the application and make a decision. To ensure compliance, many creditors use the date of application as the start of the 30-days. This is actually over-compliance but is a control technique to minimize or avoid violations.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 10, 10/04
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