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#2031298 - 08/03/15 02:30 PM Appraisal Waiver - Routine Use
complygirl Offline
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Joined: Oct 2004
Posts: 822
midwest
I remember hearing or reading the routine use of the appraisal waiver form should be avoided, this seems to be something our commercial loan department has been doing regularly (using the waiver), but is this specifically addressed somewhere (to not make it a regular practice of using the appraisal waiver form)? Thanks.

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2031519 - 08/04/15 03:00 PM Re: Appraisal Waiver - Routine Use complygirl
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
Here's a thread that discusses the waiver issue:
Waiver Discussion

Although the rule doesn't specifically prohibit the practice, commentary in the preamble suggests the waivers should be infrequent, and most likely not within the spirit of the rule. Examiners appear to be asking what the bank's practice is, but haven't heard if examiners are actually citing the practice of routinely offering an option to waive the 3-day prior receipt of appraisal as a violation.

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#2031520 - 08/04/15 03:04 PM Re: Appraisal Waiver - Routine Use complygirl
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
To me, routine use of a waiver means that the bank expects to always be receiving appraisals late in the process. To which I would have to ask, "Why? Aren't you ordering them on a timely basis?"
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2031559 - 08/04/15 04:51 PM Re: Appraisal Waiver - Routine Use complygirl
raitchjay Offline
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Joined: Oct 2009
Posts: 8,721
OK
Tagging on: 2 purchase loans closing simultaneously; LTV ratio required a different property to be taken as additional collateral for both loans: taking a 1st lien with one loan, subordinate lien with the other. Appraisals for the two purchase properties were received weeks ago. Appraisal for the extra collateral property will only be received within a few days of closing. Use the waiver (for the additional property) or (we document delivery by using an acknowledgment of receipt form) use the acknowledgment, based on the purchase property's appraisal?
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I'm fixin' to fix that.

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#2031723 - 08/05/15 12:11 PM Re: Appraisal Waiver - Routine Use complygirl
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
You would need a waiver signed prior to three days before closing to deliver late. An acknowledgement won't get you anything except agreement that you were late.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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