So I am making this flowchart for disclosures and timing things on the two regs and where they overlap. I am at the part of adverse action. For ECOA if a waiver is signed then the copy of appraisal or other written valuation must be provided to the consumer no more than 30 days of determination. If a waiver is not signed, then the copies must be given promptly upon completion. In the small compliance guide for the HPML TILA Appraisal rules the instructions are:
Last edited by Bec; 01/03/14 08:58 PM.
If you determine that you are not going to close a loan, you still have to give the applicant appraisal copies within 30 days after you determine the transaction is not going to close. In addition, if the transaction is subject to the ECOA Valuations Rule, an earlier deadline of providing the copies “promptly upon completion” applies (unless the applicant has waived that deadline under the ECOA Valuations Rule).
I am getting confused because I thought that you could not waive if the loan was an HPML so wouldn't the default deadline to supply copies of the appraisal be promptly upon complietion if it is a first lien HPML?