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#1989721 - 01/20/15 06:39 PM ECOA Appraisal Notice on PQ's
nelender1 Offline
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Joined: Nov 2013
Posts: 19
Any opinions out there on whether it's necessary to provide an appraisal notice on prequalification apps where no property has been selected?

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#1989865 - 01/20/15 11:49 PM Re: ECOA Appraisal Notice on PQ's nelender1
rlcarey Online
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rlcarey
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Galveston, TX
A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling.

A PQ "is to be secured" is it not??
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#1989967 - 01/21/15 03:53 PM Re: ECOA Appraisal Notice on PQ's nelender1
John Burnett Offline
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John Burnett
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Cape Cod
Of course, unless a property is later identified, you won't actually get an appraisal, so you won't provide a copy. But as ridiculous as it may seem, the notice requirement still applies to the pre-qual.
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#2118984 - 02/21/17 06:43 PM Re: ECOA Appraisal Notice on PQ's nelender1
ComplyGuy Offline
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Posts: 288
Reg B definition of application is based on the bank's procedures and additionally says that you have an application when you have "received all the information that the creditor regularly obtains and considers in evaluating applications for the amount and type of credit requested."

Per this definition, couldn't the bank's procedures require a property address to have a completed application, therefore meaning the appraisal notice is not required?

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#2118997 - 02/21/17 07:19 PM Re: ECOA Appraisal Notice on PQ's nelender1
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,365
Galveston, TX
Receiving an application for credit and having a complete application are two totally different animals.

"not later than the third business day after the creditor receives an application for credit that is to be secured by a first lien on a dwelling"

There is no mention or support to think that this excerpt means a "complete application". There is no relationship between Regulation B and the six elements that cover TRID. .
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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