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#1971670 - 10/23/14 09:19 PM Giving appraisal a 2nd time - w/d and reapplied
Wannaknow Offline
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Joined: Jul 2011
Posts: 238
4 applicants apply for a loan to purchase a primary residence. The appraisal was ordered and delivered to the applicants. They later withdraw their loan request.

1 month later – 2 of the applicants reapply to purchase the same residence.

Do we have to give a copy of the appraisal again or can it be said they already received it?
Last edited by wannaknow; 10/23/14 09:30 PM.
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#1971688 - 10/23/14 10:46 PM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
I'm not sure if you can follow the same logic, but for renewals, you only have to provide the appraisal if you did a new one.

Section 1002.14(a)(1) does not apply to the extent a creditor uses the appraisals and other written valuations that were previously developed in connection with the prior extension of credit to evaluate the renewal request.
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#1971735 - 10/24/14 01:38 PM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
This is a new loan request. I don't see it being exempt from having to provide new disclosures or a copy of the appraisal under the above cite. No extension of credit was previously granted involving the transaction.

Besides, you already have the appraisal. It will take about 3 minutes to run it through the copier and give it to one of the applicants. What's the big deal in providing a 2nd copy?
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#1974399 - 11/05/14 06:11 PM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
complyorelse Offline
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Posts: 448
U.S.
A similar situation. We have a first mortgage on a dwelling and the borrower was given a copy of the appraisal when that loan originated. The borrower has now applied for a HELOC using the same dwelling and the bank is not going to order a new appraisal.

We've provided the disclosure but, since the Reg nor Commentary address a new loan with no new appraisal, we're not sure if we have to provide a copy of the older appraisal, if the timing requirements kick in, or if eSign would apply (if we're emailing)?

As Dan stated above, it's not a big deal to make a copy of the appraisal we have, but we need to know what's required by law so we can get our procedures aligned.

Any input is most appreciated. Thank you.

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#1974473 - 11/05/14 07:48 PM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
complyorelse Offline
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Posts: 448
U.S.
Allow me to clarify one point, the first mortgage will be paying off so we will be in first lien position with our HELOC.

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#1974626 - 11/05/14 11:44 PM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
Princess of Power Offline
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Princess of Power
Joined: Aug 2002
Posts: 406
Napa, CA
Your HELOC request is a NEW request - notice & copy of appraisal required

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#1974640 - 11/06/14 03:57 AM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Hold on just a dang minute. Under Reg B section 1002.14, you will have to provide the notice, but unless you do a new valuation or appraisal in connection with this application, you do not have to provide a copy of the appraisal you aren't developing.

And the appraisal you already have in file was not developed in connection with this application, so you don't have to provide a copy of it, either.
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#1975012 - 11/07/14 01:25 PM Re: Giving appraisal a 2nd time - w/d and reapplied Wannaknow
complyorelse Offline
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Joined: Nov 2007
Posts: 448
U.S.
Great feedback. I tend to agree with John. Thanks a lot.

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