We are trying to set up our procedures and I have a question about the time of the disclosure for renewals. On a previous post is was answered that the disclosure must be given even if the previous appraisal was being used. Say, we renew a dwelling secured loan for another 12 months and a internal evaluation is being completed. Does the disclosure have to be sent 3 days before the modification is signed and can the copy of the appraisal be given to them when they sign the modification or do you have to send the disclosure 3 days before the signing and then give the 3 days for mailing the internal evaluation before the modification is signed? I am good on the new loans. Just on renewals I am not sure of the timing. Thank you!

Bump!

IMO, if the bank has a new appraisal or an internal evaluation, it must be given in compliance with Reg "B" requirements,1002.14(a)(1)