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#1891833 - 01/29/14 08:54 PM Deliver of Notice With Application
Dolly Nugent Offline
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Dolly Nugent
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Southern California
Is it acceptable to deliver the notice along with the application as a separate document, as opposed to providing after the application is received?
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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1891840 - 01/29/14 09:12 PM Re: Deliver of Notice With Application Dolly Nugent
manimal Offline
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manimal
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My only thought there would be, what if the loan ends up not being covered by the appraisal disclosure requirements? Remember, it only covers first liens on 1-4 unit(s) residential. What if the collateral ends up being a subordinate lien? Now you've disclosed that you will provide the appraisal no later than 3 days before closing.

I'm not sure what an examiner would say, but that was my initial reaction. smile
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#1891928 - 01/30/14 12:31 PM Re: Deliver of Notice With Application Dolly Nugent
Dolly Nugent Offline
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Dolly Nugent
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Southern California
Great point! I would prefer that they just wait until they actually RECEIVE an application.
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Dolly Nugent
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#1892407 - 01/31/14 12:51 AM Re: Deliver of Notice With Application Dolly Nugent
Dolly Nugent Offline
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Dolly Nugent
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Southern California
Actually, the C-9 notice does not state that we will provide the appraisal three days before closing. Just wanted to point that out.
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#1892455 - 01/31/14 02:40 PM Re: Deliver of Notice With Application Dolly Nugent
manimal Offline
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Hm, good point. I didn't realize that. Well, C-9 does say you will provide the appraisal promptly upon completion, so if the loan doesn't end up being covered by the rules (again, my example would be a subordinate lien), would you still provide a copy to the applicant? If yes, then I don't really see a reason why you can't provide it with the application.
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#1892804 - 01/31/14 11:02 PM Re: Deliver of Notice With Application Dolly Nugent
Dolly Nugent Offline
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Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
In CA we have a state law that is different for junior liens. It requires a different notice be delivered within 15 days of receiving an application. Prior to this new Reg B rule we routinely provided a copy of the appraisal at closing. My concern is that by delivering the Reg B notice an examiner would expect us to observe all the timing rules pertaining to the delivery of the appraisal and consummation.
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Dolly Nugent
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#1893370 - 02/04/14 04:39 PM Re: Deliver of Notice With Application Dolly Nugent
ahkcompliance Offline
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We do attach the notice to the application. We provide a copy of the appraisal on all transactions so it was just easier to attach to make sure it it given.

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