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BSA/AML Compliance: Writing the SAR Narrative
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Overdraft Practices in Today's Regulatory Environment
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#1852356 - 09/16/13 11:50 AM new ECOA appraisal rules
live4regs Online
New Poster

Registered: 09/11/13
Posts: 1
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: 15768
Loc: The Swamp
I would say,yes...those days are [soon to be] over.


Edited by RR Joker (09/16/13 03:35 PM)
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