Skip to content
BOL Conferences
Thread Options
#2120576 - 03/06/17 01:15 PM How do you prove delivery of appraisal?
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 530
Midwest
We have the right to a copy of the appraisal disclosure, but we don't have anything that would serve as proof the customer received the appraisal copy. What is the best way of establishing this proof- should we implement a disclosure the customer would sign acknowledging receipt of the appraisal? There is no such disclosure today generated with our loan packets. Other options?

Return to Top
Interagency (Reg Z) and CFPB Reg B Appraisal Rules
#2120582 - 03/06/17 02:11 PM Re: How do you prove delivery of appraisal? M&M
MScarn6942 Offline
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
You could generate something like that, but I would think that strong policies/procedures detailing how you go about delivering the appraisal on time would be sufficient.
_________________________
"Pressure is something you feel when you don't know what you're doing" - Peyton Manning

Return to Top
#2120590 - 03/06/17 02:42 PM Re: How do you prove delivery of appraisal? M&M
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Documentation of appraisal delivery can take on many forms. There is no regulatory requirement that the borrower sign a form stating that they received the appraisal, although many banks use such a form and such a form may be required by certain investors. The most common forms of proof of delivery that are used are as follows.

1. The creditor delivers the appraisal in person to the borrower and either the loan officer documents the delivery date of the appraisal to the borrower in the loan file or requires the borrower to sign and date an acknowledgment receipt.

2. The creditor mails the appraisal to the borrower and documents the date of mailing in the loan file (i.e., retains a copy of the cover letter in the file, etc.) and uses the 3 business day timing delay as the delivery date before beginning the 3 business day before loan closing clock.

3. If mailed, some creditors have the customer return a signed and dated acknowledgement receipt or some creditors have them sign an acknowledgement receipt at a later date, such as at closing.

4. The creditor sends the appraisal through a validated E-Sign delivery system and then either follows the 3+3 business day timing for closing or documents the date that the borrower acknowledged receipt of the electronic delivery to begin the 3 business day before loan closing clock.

It comes down to a business decision by the creditor as to how comfortable they are with their documentation process or how the creditor must meet the requirements of any investors that may be involved.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2120609 - 03/06/17 03:31 PM Re: How do you prove delivery of appraisal? M&M
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 530
Midwest
Thanks Randy and MScarn6942. Appreciate your help.

Return to Top