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#1964055 - 09/23/14 07:37 PM Delivery of Appraisal
Kristi Offline
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Kristi
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Posts: 85
Is anyone having the customer sign an acknowlegement when a copy of the appraisal is hand delivered? I know there is no requirement for this but wanted to see if anyone is doing this to document that it was given at least 3 business days prior to closing.

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1964066 - 09/23/14 08:02 PM Re: Delivery of Appraisal Kristi
niche girl Offline
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We used to, but with the new requirements causing us to deliver potentially multiple copies of not only the appraisal but other written valuations throughout the valuation process, we thought it would be too hard to monitor paper forms and make sure it gets signed every time. We set up our system so that for each new version of a valuation generated, a system stop is generated after 48 hours that requires the person who produced the copy to attest to the date and method it was provided to the consumer (in person or Mail)or if it was not provided (extra copy generated by mistake). ESIGN automatically makes an entry when it is sent and when it is openned by the customer. That way we can easily see when, how and by whom each item was provided or if a particular copy was not provided and the reason.
Last edited by niche girl; 09/23/14 08:03 PM.
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#1964266 - 09/24/14 03:40 PM Re: Delivery of Appraisal niche girl
Cornfed Turtle Offline
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"...Somewhere in Middle Americ...
Our original process was NOT to have the form signed. We just have a procedure. Compliance Officer didn't like that...wanted something to show the examiners. So now we have unsigned forms to show the examiners.

Remember that commercial lenders are involved in this. I've witnessed them giving out the appraisals and evals, but now they have to get a form signed. Don't know why it's tricky but it is. If your procedure is to have signed paper, your auditors and examiners are going to be looking for signed paper in the file.

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#1964356 - 09/24/14 07:02 PM Re: Delivery of Appraisal Kristi
John Burnett Offline
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With all due respect to your compliance officer, audit exceptions and exam citations for unacknowledged appraisal copies will be self-inflicted wounds.
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#1964358 - 09/24/14 07:05 PM Re: Delivery of Appraisal Kristi
Jerod Moyer Offline
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Jerod Moyer
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Sioux Falls, SD
I agree with John's and Cornfed's comments, if your procedures are to get a form signed by the borrower you will undoubtably have unsigned forms in the files. The auditor and examiner are going assume when the form is unsigned that the borrower didn't get the appraisal copy. So, I too recommend not requiring a signature. I recommend the lender document the date of delivery in the file. Think of this too, do you have every customer sign stating that they have received your Privacy notice. No, because there's no signature requirement. The appraisal copy doesn't have a signature requirement either, so why create more burden?

That said if you still wish to have a form, at the very least write procedures that allow for both borrower signatures (when you can get them) and lender comments (when signatures aren't possible). This way you don't shoot yourself in the foot with a procedure that's not possible 100% of the time. Good luck.
Last edited by Jerod Moyer; 09/24/14 07:06 PM.
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#1964360 - 09/24/14 07:12 PM Re: Delivery of Appraisal Kristi
JWills, CRCM Offline
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The Mitten State
Originally we were going to have the borrower sign, but as Jerod pointed out, why make a procedure that will inevitably fail?
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#1964402 - 09/24/14 07:58 PM Re: Delivery of Appraisal Kristi
Beachbum, CRCM Offline
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Joined: Dec 2006
Posts: 480
Knee Deep in Regs
we have added a delivery date and method of delivery to our underwriting checklist. Auditors were happy with that.
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#1964414 - 09/24/14 08:20 PM Re: Delivery of Appraisal Kristi
John Burnett Offline
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Cape Cod
Some auditors will be wise enough to realize that the signature requirement, if in policy or procedures, makes their work harder, too.
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#1964418 - 09/24/14 08:27 PM Re: Delivery of Appraisal Kristi
JWills, CRCM Offline
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The Mitten State
^^^^^^ Hopefully! smile
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