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December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett

January 6, 2015
Business Accounts Documentation and Procedures with Beneficial Ownership
Deborah Crawford

January 6, 2015
FFIEC Cybersecurity Initiatives and Observations from the 2014 Assessments
Susan Orr

January 15, 2015
The ABC's of IRAs - The Basic Ingredients
Patrice Konarik

January 20, 2015
B & Z Appraisal Rules - Getting Them Right
Jack Holzknecht

January 21, 2015
HMDA Soup to Nuts
David Dickinson



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#1852356 - 09/16/13 11:50 AM new ECOA appraisal rules
live4regs Offline
New Poster

Registered: 09/11/13
Posts: 3
Loc: Kansas
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?

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Lending Compliance
#1852536 - 09/16/13 03:34 PM Re: new ECOA appraisal rules [Re: live4regs]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 16484
Loc: The Swamp
I would say,yes...those days are [soon to be] over.


Edited by RR Joker (09/16/13 03:35 PM)
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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