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#2120041 - 03/01/17 04:56 PM Notice Regarding Not Ordering Appraisal
ComplyCycle Offline
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ComplyCycle
Joined: Dec 2014
Posts: 454
Hello, I am curious if someone can please provide a regulatory citation/business reason for providing a notice along the lines of the following: https://www.stmpartners.com/manual/cor/forms/cor0059.pdf

The notice on the link provided basically states that we won't be ordering an appraisal because the loan meets certain requirements, but the applicant is free to obtain, and pay for, an appraisal if the applicant desires.

Why are we (and other financial institutions, evidently) providing a notice like this? Thanks in advance.

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Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2120043 - 03/01/17 04:58 PM Re: Notice Regarding Not Ordering Appraisal ComplyCycle
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
I've never heard of that before.
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#2120058 - 03/01/17 05:52 PM Re: Notice Regarding Not Ordering Appraisal ComplyCycle
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
It's either:

1. A state law requirement,
2. An investor requirement, or
3. An internal requirement.

However, I would question its legality in relation to the regulatory requirement and there is no way I would even consider using it until it was reviewed and approved by the bank's legal counsel.
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#2120062 - 03/01/17 06:03 PM Re: Notice Regarding Not Ordering Appraisal ComplyCycle
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
And it is a SunTrust document, based on the footer, from 2003. We used SunTrust up until a few years ago, but I never recall seeing that document in our packages we sold to them. If you are using SunTrust, I'd check with them why they are still using or requiring it. If they are not, I'd sniff around on why you are still using it and short of any good explanation, ditch it.
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