new ECOA appraisal rules

Because we have to provide copies of appraisals to our applicants atleast 3 days prior to closing, am I correct in thinking that we can no longer close a loan within 3 days? In the same scenario, we would not be able to obtain a waiver since those are required atleast 3 days before closing.

Assume this is a refinance of a commercial loan, secured by a 1-4 family dwelling in which we preformed an in-house evaluation to determine the property's value.

Surely we are not the only bank to turn around commercial loans this quickly from time to time?

I would say,yes...those days are [soon to be] over.