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#1972435 - 10/28/14 04:41 PM Right to Receive Copy of Appraisal form
countrytink Offline
Junior Member
Joined: Feb 2004
Posts: 48
Illinois
Our FNMA 1003 contains the Right to Receive Copy of Appraisal, but it says the "creditor must hear from from us no later than 90 days after Creditor notifies us about the action taken on this application", and to contact the bank with our address. Is this language still applicable in light of the new forms requiring the 3 days to provide a copy of the appraisal before consummation?

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1972722 - 10/29/14 04:30 PM Re: Right to Receive Copy of Appraisal form countrytink
ComplianceNerd Offline
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Joined: Nov 2011
Posts: 378
Texas ...
Eeeek... for some unknown reason to me, I don't think it's sufficient anymore because we used to have the same clause on our 1003's. Don't quote me on this though.
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#1972936 - 10/30/14 02:59 AM Re: Right to Receive Copy of Appraisal form countrytink
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Definitely not acceptable. The language you want is found in Notice C-9 in Appendix C of Regulation B.
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#1973172 - 10/30/14 06:46 PM Re: Right to Receive Copy of Appraisal form countrytink
countrytink Offline
Junior Member
Joined: Feb 2004
Posts: 48
Illinois
Is the Notice as worded in Reg B, C-9 required? I'm getting confused with the notice given within 3 days of application and the Acknowledgment/Waiver 3 days before closing. I think the "90 day" language in the Right to Receive Copy of Appraisal seems contradictory to the new requirements enacted Jan 2014.

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#1973313 - 10/31/14 04:14 AM Re: Right to Receive Copy of Appraisal form countrytink
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
All right, I have to ask this: Where are you finding this 90-day language? Notice C-9 doesn't have such wording. Check the currency of the regulation you're looking at.
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#1973314 - 10/31/14 04:33 AM Re: Right to Receive Copy of Appraisal form countrytink
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Never mind. I know where you are finding it. You're looking at the Fed's old regulation, 12 CFR Part 202. This is the reason that you will find several posters here reminding others to stop going to the old regs that the CFPB took over almost three years ago.

THIS is the Reg B you should be looking at. We work hard here at BOL keeping the current regulations on our site up to date. We think you'll like using them as a resource.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1973444 - 10/31/14 05:16 PM Re: Right to Receive Copy of Appraisal form countrytink
countrytink Offline
Junior Member
Joined: Feb 2004
Posts: 48
Illinois
Thanks John. Our compliance officer said to leave the "90 day" language on our application form, but it just didn't seem correct to me. We are using the correct Notice form in accordance with CFPB. I just have to convince him that we should remove the "90 day" statement from our documents. Thanks for your help

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#1973594 - 11/03/14 11:23 AM Re: Right to Receive Copy of Appraisal form countrytink
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You might try to point out that the old notice was required by the former wording of section 1002.14, which was replaced entirely by the current section.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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