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#2030420 - 07/29/15 01:52 PM Definition of "Promptly"
n2compliance Offline
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n2compliance
Joined: May 2011
Posts: 102
I am paraphrasing here, but basically I understand that the Regulation B Appraisal Rules require a bank to provide a copy of an appraisal "promptly" after reviewing the appraisal and deeming it accurate, and it must be provided at least 3 business days before the loan closes. Can someone please define "promptly"? If we provide the appraisal one week after we receive/approve it - will that be a violation? What about two weeks, three weeks? At what point is it a violation? It seems like "promptly" is personal opinion, but I know the examiners wouldn't go for that!

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2030432 - 07/29/15 02:16 PM Re: Definition of "Promptly" n2compliance
Skittles Offline
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Skittles
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TN
I can't remember which seminar it was, but the speaker suggested the applicant receive the completed appraisal within 7 days of it being reviewed and accepted.
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#2030444 - 07/29/15 02:29 PM Re: Definition of "Promptly" n2compliance
complymuch, crcm Offline
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Joined: Apr 2013
Posts: 79
FL
I would suggest reviewing the Commentary. It provides several illustrative examples. And ensure that you have a process with written procedures.

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#2030449 - 07/29/15 02:35 PM Re: Definition of "Promptly" n2compliance
n2compliance Offline
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n2compliance
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So I'm thinking about revising my Reg B Policy to state that the appraisals must be provided no more than 6 business days after the documented date the appraisal is deemed accurate and acceptable, AND at least 3 business days before the loan date. Then as long as we always fall within that time frame every time we should be ok. Agreed???

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#2030482 - 07/29/15 03:54 PM Re: Definition of "Promptly" n2compliance
#Just Jay Offline
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#Just Jay
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Cheeseheadland
Do you really want to limit yourself like that? Don't box yourself in any more than you have to or more tightly that the commentary allows. Give yourself some wiggle room for unique events and avoid policy exceptions and or violations.
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#2030492 - 07/29/15 04:13 PM Re: Definition of "Promptly" n2compliance
John Burnett Offline
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John Burnett
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Cape Cod
Put "guidelines" for prompt delivery of the appraisal copy in your policy or procedure, but allow for extraordinary situations.
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#2030497 - 07/29/15 04:28 PM Re: Definition of "Promptly" n2compliance
n2compliance Offline
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n2compliance
Joined: May 2011
Posts: 102
OK so maybe I'll just make it our policy and procedure to "recommend that the bank provide appraisals no more than 6 business days after the documented date the appraisal is deemed accurate and acceptable, AND at least 3 business days before the loan date". That shouldn't box us in, right?

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