Is it acceptable to deliver the notice along with the application as a separate document, as opposed to providing after the application is received?

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.

Great point! I would prefer that they just wait until they actually RECEIVE an application.

Actually, the C-9 notice does not state that we will provide the appraisal three days before closing. Just wanted to point that out.

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.

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.

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.