For Reg B purposes we require a verification of income and of assets to have a "completed application." If we receive an appraisal for a lower than expected amount, if the loan was already approved would this prompt a counteroffer if we can't use the original terms that we offered based on the verification of income and verification of assets?
In regards to Reg B appraisal notices and commercial loans: does the loan need to be secured by a first lien on a dwelling for the notice requirements to apply or is it any dwelling secured loan - regardless of lien position? For example, an LLC is securing a commercial loan with a 2nd lien on a dwelling, do they get the appraisal notice or not?
In my search for guidance on e-Sign compliance for delivery of appraisals (Reg B) and Closing Disclosures (Reg Z) there seems to be a difference in what is recommended for Reg B & Reg Z. All the guidance on delivery of the closing disclosure states that a read or delivery receipt is not a recommended method of documenting proof of the date delivery occurred. However, guidance on Reg B delivery date of the appraisal tends to lean the other way and regarding a read/delivery receipt. In fact the commentary
1002.14(a)(4)(I) even states ... “Delivery occurs three business days after mailing or delivering copies... or when evidence indicates actual receipt by the applicant, whichever is earlier". With the commentary in mind is it necessary for us to get a confirmation e-mail to document the actual date of delivery of the appraisal or can we simply apply the guidance from the commentary and rest on the delivery occurred three business days after xmailing whether snail or electronic mail?
My question is in regards to Regulation B, section 1002.14- Rules on providing appraisals. Section 1002.14 (a)(5) -- Copies in electronic form --states the copies required by 1002.14(a)(1) (waiver and appraisal) may be provided electronically with customer consent. It does not state anything about the disclosure. Can the disclosure be delivered electronically?
Can a listing agent refuse the appraiser due to past appraisals not coming in at value?
Does AZ require an appraisal notice to receive a copy of the report on non-residential property?
My question is, "As a small rural community lender, do we have to require an appraisal from a licensed appraiser for primary, 1st, closed end loans under $50,000 that we portfolio?" Can we have a written evaluation completed in house if the RMV through the county is sufficient enough to satisfy our policy?
When can you collect an appraisal fee for a HELOC?
Reg B Appraisals: first mortgages closed end - If we obtain a field appraisal on a property, are we required to share this with our borrowers under Reg B, what about AVMs? I thought we didn't have to share those.
Am I required to provide a Right to Receive a Copy of the Appraisal when making a loan to a company (LLC)?