I know that HVCC required you to provide the borrower with a copy of the appraisal 3 days prior to closing. I also know that the new changes in REG Z have made HVCC have no force or effect. My question are there any requirements to provide the borrower with a copy of the appraisal before closing (other than those found in REG B)?

Not yet, but the FDA will require delivery in some cases soon.

FDA?

Yeah, the Food and Drug Administration is now getting in on all the fun! Pretty sure he ment, DFA, Dodd Frank Act.

See Subtitle F of the Act for all the appraisal changes but Section 1474 specifically adds the appraisal dislcosure requirements to Reg.B.

SEC. 1474. EQUAL CREDIT OPPORTUNITY ACT AMENDMENT.

Subsection (e) of section 701 of the Equal Credit Opportunity Act (15 U.S.C. 1691) is amended to read as follows:

‘‘(e) COPIES FURNISHED TO APPLICANTS.—

‘‘(1) IN GENERAL.—Each creditor shall furnish to an applicant a copy of any and all written appraisals and valuations developed in connection with the applicant’s application for a loan that is secured or would have been secured by a first lien on a dwelling promptly upon completion, but in no case later than 3 days prior to the closing of the loan, whether the creditor grants or denies the applicant’s request for credit or the application is incomplete or withdrawn.

‘‘(2) WAIVER.—The applicant may waive the 3 day requirement provided for in paragraph (1), except where otherwise required in law.

‘‘(3) REIMBURSEMENT.—The applicant may be required to pay a reasonable fee to reimburse the creditor for the cost of the appraisal, except where otherwise required in law.\

‘‘(4) FREE COPY.—Notwithstanding paragraph (3), the creditor shall provide a copy of each written appraisal or valuation at no additional cost to the applicant.

‘‘(5) NOTIFICATION TO APPLICANTS.—At the time of application, the creditor shall notify an applicant in writing of the right to receive a copy of each written appraisal and valuation under this subsection.

‘‘(6) VALUATION DEFINED.—For purposes of this subsection, the term ‘valuation’ shall include any estimate of the value of a dwelling developed in connection with a creditor’s decision to provide credit, including those values developed pursuant to a policy of a government sponsored enterprise or by an automated valuation model, a broker price opinion, or other methodology or mechanism.’’.

Does this go into effect tomorrow?

No - regulations will be issued.

Bless you - a consultant is sending out an e-mail telling folks this goes into effect tomorrow. I began to think I had missed something!

Send them this - this is the effective date for everything in Section 1400, unless otherwise indicated:

SEC. 1400. SHORT TITLE; DESIGNATION AS ENUMERATED CONSUMER
LAW.

(c) REGULATIONS; EFFECTIVE DATE.—
(1) REGULATIONS.—The regulations required to be prescribed
under this title or the amendments made by this title
shall—
(A) be prescribed in final form before the end of the
18-month period beginning on the designated transfer date;
and
(B) take effect not later than 12 months after the
date of issuance of the regulations in final form.
(2) EFFECTIVE DATE ESTABLISHED BY RULE.—Except as provided
in paragraph (3), a section, or provision thereof, of this
title shall take effect on the date on which the final regulations
implementing such section, or provision, take effect.
(3) EFFECTIVE DATE.—A section of this title for which regulations
have not been issued on the date that is 18 months
after the designated transfer date shall take effect on such
date.

Great news... I had a consultant yesterday telling me it was going to be in effect and we had missed it.

Time to get some new consultants

This wasn't someone we use - just someone apparently trying to pick up business. Don't think its going to work out so well for her!

That would be because of the drugs now needed by those working in this industry.

Oh - of course that was posted at 1am