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#1722038 - 07/20/12 07:50 PM Appraisal three days in advance of closing
Sisyphus Offline
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Sisyphus
Joined: Jun 2008
Posts: 222
Is there a requirement to provide a borrower with the appraisal at least three business days prior to the closing?

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Lending Compliance
#1722050 - 07/20/12 08:03 PM Re: Appraisal three days in advance of closing Sisyphus
Jerod Moyer Offline
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Jerod Moyer
Joined: Oct 2005
Posts: 667
Sioux Falls, SD
At some point the Dodd Frank Act will amend Regulation B to require the following:

ECOA – Free Copy of Appraisals [§1474]:

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the loan, whether the creditor grants or denies the applicant’s request for credit or the application is incomplete or withdrawn.

However, currently you are only required to either provide a copy of the appraisal or provide a notice stating the right to request a copy of the appraisal.
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Jerod Moyer
www.bankerscompliance.com

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#1722052 - 07/20/12 08:04 PM Re: Appraisal three days in advance of closing Jerod Moyer
Sisyphus Offline
100 Club
Sisyphus
Joined: Jun 2008
Posts: 222
Thanks so much for your quick reply!

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#1722729 - 07/24/12 03:21 PM Re: Appraisal three days in advance of closing Sisyphus
MN Banker Offline
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Joined: Aug 2006
Posts: 980
If your loans are or will be sold to Fannie/Freddie, then the Appraisal Independence Requirements state that the appraisal has to be provided 3 days prior to closing unless the borrower waives this.

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#1723477 - 07/25/12 11:42 PM Re: Appraisal three days in advance of closing MN Banker
Sisyphus Offline
100 Club
Sisyphus
Joined: Jun 2008
Posts: 222
Are you referring to the Reg. Z independence rule?

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#1723489 - 07/26/12 11:24 AM Re: Appraisal three days in advance of closing Sisyphus
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,325
Galveston, TX
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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