With the elimination of HVCC, am I correct that the requirement to provide a copy of the appraisal to the borrower 3 business days prior to closing is no longer?

To document compliance with HVCC we were having the borrowers sign a form stating that they either received the appraisal 3 days prior to that they had waived their right. I just want to make sure this is no longer required before I stop using the form.

Thanks!

Nevermind, I found it. It appears that Fannie and Freddie basically just renamed the HVCC rules to "Appraiser Independence Requirements", which is separate from the actual TIL regulation. The "AIR" still require the borrower to receive the appraisal 3 business days prior to closing. Good to see HVCC hasn't really gone away.

It is also in the Frank Dodd Bill - details forthcoming.

Can someone help me confirm--AIR applies only to FNMA/FHLMC loans at this point, correct? But when Dodd Frank rules are published it will apply to all loans? (I'm using "all loans" as a generic for whatever definition they come up with in the DF rules.)

Nope. AIR now affects all loans secured by a consumer's principal dwelling. The FRB issued an interim final rule on AIR, effective December 27, 2010. However, compliance was optional until April 1, 2011.

Like rl stated - there is more coming and from what my compliance officer tells us it will affect all loans.

Not sure i'm following: the requirement to provide a copy of the appraisal 3 days prior to closing (not talking about loans that are to be sold to Fannie or Freddie) has begun already? or no? I thought we were still waiting on this.

BUMP