Holding company hired an in-house appraiser. For consumer, they will mostly do evaluations (i.e. loans less than $250,000).

My question is, when do we need to give the ABD (at application or with the GFE)? The lender may not know right away if they will use the holding company person or get a third party (i.e. timing of a third party may be quicker, more complex prperty, etc).

Could we just give the AFD with the GFE? By the time the earlies go out the lender would know who they are using.
THANKS

(i) Where a lender makes the referral to a borrower, the condition contained in paragraph (b)(1) of this section may be satisfied at the time that the good faith estimate or a statement under Sec. 3500.7(d) is provided;