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#21043 - 06/18/02 05:12 PM Reg B Appraisal Reports
tjbanker Offline
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Joined: Jun 2002
Posts: 310
I was wondering how many banks follow 202.5a Rules on providing appraisal reports a1. Routine delivery for providing appraisals in lieu of a form stating such? I am completing a document request for an exam and they want a copy of the form used to notify applicants. We routinely providing the appraisal report so we do not complete a form letting the customer know he/she needs to request the appraisal. Thank you for your replies.

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#21044 - 06/18/02 05:21 PM Re: Reg B Appraisal Reports
JulieB Offline
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JulieB
Joined: Apr 2002
Posts: 38
SC
My bank provides the notice.

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#21045 - 06/18/02 05:32 PM Re: Reg B Appraisal Reports
Andy_Z Offline
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We provide the appraisal reports as a procedure. Most of our mortgage volume is VA and I am told this is SOP.
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#21046 - 06/18/02 05:38 PM Reg B Appraisal Reports
elcinoca Offline
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Joined: Jan 2002
Posts: 537
Elizabeth City, NC
We provide the notice.

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#21047 - 06/18/02 05:54 PM Re: Reg B Appraisal Reports
teresa Offline
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teresa
Joined: May 2002
Posts: 91
Maryland
We provide the notice - its right on the bottom of the application.

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#21048 - 06/18/02 07:20 PM Re: Reg B Appraisal Reports
Andy_Z Offline
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FYI, we use a Bankers Systems adverse action notice. This notice is at the bottom of that form.

While we use this, procedurally we provide the appraisal as I noted above.
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AndyZ CRCM
My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#21049 - 06/18/02 07:51 PM Re: Reg B Appraisal Reports
redsfan Offline
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redsfan
Joined: Dec 2000
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The Pennant Race
Our retail operations provide the notice. Our mortgage operations routinely provide copies of the appraisal, but still provide the notice.
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#21050 - 06/18/02 08:12 PM Re: Reg B Appraisal Reports
Jodi Offline
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Jodi
Joined: Jun 2002
Posts: 87
Does the notice need to go to loan applicants purchasing a rental house.....a business loan? The loan application used in such cases does not include the notice. Furthermore, it is the "nature" of our bank not to require an appraisal in many situations.

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#21051 - 06/18/02 08:17 PM Re: Reg B Appraisal Reports
Princess Romeo Offline

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We also routinely provide a copy of the appraisal. In the file, we have a cover letter to go with the appraisal. Also, the practice of sending the appraisal is stated in our policy and procedures.
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#21052 - 06/18/02 09:13 PM Re: Reg B Appraisal Reports
Andy_Z Offline
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12 CFR ยง202.5a Rules on providing appraisal reports.
(a) Providing appraisals. A creditor shall provide a copy of the appraisal report used in connection with an application for credit that is to be secured by a lien on a dwelling.

If you have no appraisal or use what the borrower brought in, tax valuation, etc. there is no need to provide to them, what they gave to you.

Business or personal doesn't matter. And be sure to see what is defined as an "appraisal", especially if you typically add to it.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#21053 - 06/18/02 09:34 PM Re: Reg B Appraisal Reports
Jodi Offline
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Jodi
Joined: Jun 2002
Posts: 87
Ok, bear with me here! 202.5(a)(2)(i)states a notice to receive a copy of the appraisal will be given to the applicant...If we do not routinely give a copy of the appraisal, should we give this "notice" in ALL situations, including those where an appraisal will not be done and an in house inspection is performed? In order to be in compliance, you would have to routinely deliver or provide the notice? Thanks for being patient with me!

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#21054 - 06/19/02 02:50 AM Re: Reg B Appraisal Reports
Andy_Z Offline
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Key items here will depend on how you are defining "ALL". Look at the applicability of 202.5a (above & in the reg. and commentary) and especially look at the definition in 5a(c) of the commentary for what is, and is not and appraisal. That will define for you when you will need to provide notice or a copy of a definitional appraisal.

If there is no appraisal, there would be nothing to give notice for.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#21055 - 06/19/02 02:11 PM Re: Reg B Appraisal Reports
RVFlyboy Offline
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RVFlyboy
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Soaring over Georgia
Using the "Poll" feature (see FAQ, under the Bankers Thread Discussion Title Bar), here's how you could have done this thread without the extended replies:


Appraisal Notice Practices
We routinely provide the actual appraisal.
We routinely provide the appraisal notice.
We do a combination of notice and actual appraisal.

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