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#2130364 - 05/12/17 08:18 PM providing appraisal reports
crc Offline
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Joined: May 2004
Posts: 150
South Dakota
If we reuse an appraisal/evaluation (no changes) do we still have to provide a copy for a new loan application?

thanks.

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#2130371 - 05/12/17 08:53 PM Re: providing appraisal reports crc
John Burnett Offline
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John Burnett
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Posts: 39,793
Cape Cod
If you are referring to the Regulation B requirement for a copy of an appraisal developed in connection with an application for credit to be secured by a first lien on a dwelling, no, because the appraisal was not developed "in connection with" the current application for credit. You already had it.

If you reviewed the appraisal and came up with a different value after adjusting to the passage of time and changes in the market for homes in your area, yes, because you developed a new valuation in connection with the current application.
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#2130383 - 05/12/17 09:17 PM Re: providing appraisal reports John Burnett
crc Offline
100 Club
Joined: May 2004
Posts: 150
South Dakota
Yes, the Reg B requirement. Thanks for your help!

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#2130408 - 05/15/17 11:23 AM Re: providing appraisal reports crc
Monster Offline
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Joined: Sep 2015
Posts: 489
This post reminded me of a question I was recently presented with. Applicant withdrew loan after appraisal had been ordered. MLO immediately contacted the appraisal company to ask them to cancel the appraisal but the appraiser was on-site at that moment. He stopped where he was and charged a lower fee. The question was "do we need to provide the incomplete appraisal?" to which I responded yes... but I didn't really like the way the whole scenario went down - I would have preferred they had called the applicant to determine whether or not they wanted the discounted/incomplete appraisal or full appraisal. What would others have done in this scenario?

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#2130415 - 05/15/17 12:25 PM Re: providing appraisal reports crc
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
An incomplete appraisal is not an appraisal - why would the bank even accept it? If you had to pay because the appraiser was already on site is one thing - why they would put pencil to paper and deliver anything to the bank really doesn't make any sense.
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#2130432 - 05/15/17 02:07 PM Re: providing appraisal reports crc
Monster Offline
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Joined: Sep 2015
Posts: 489
I agree, I suppose they felt their time needed to be justified to still get the fee. Thanks Randy!

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#2130834 - 05/17/17 08:03 PM Re: providing appraisal reports crc
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,759
The Mitten State
If a customer purchases a home from the lender, and the appraisal in file was done for the lender months prior to the purchase, do we provide any notices, or copies of that appraisal?
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#2130835 - 05/17/17 08:06 PM Re: providing appraisal reports crc
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
Yes - assuming you are using it to approve their credit application.
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#2131003 - 05/18/17 07:36 PM Re: providing appraisal reports rlcarey
tuma Offline
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Joined: Feb 2003
Posts: 368
Here & There
Randy - your reply appears to contradict John's original answer.
In both instances, the valuation of the property was obtained prior to the application.
Or is there a distinction that I am missing?

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#2131020 - 05/18/17 08:20 PM Re: providing appraisal reports crc
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
It is going to be transaction specific:

2. Renewals. Section 1002.14(a)(1) applies when an applicant requests the renewal of an existing extension of credit and the creditor develops a new appraisal or other written valuation. Section 1002.14(a)(1) does not apply to the extent a creditor uses the appraisals and other written valuations that were previously developed in connection with the prior extension of credit to evaluate the renewal request.

In this case - you have a totally new borrower who would be entitled to the valuation of the property that you are using.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2131198 - 05/19/17 06:42 PM Re: providing appraisal reports crc
Onehotidea Offline
Junior Member
Joined: Jul 2015
Posts: 36
Minnesota
When doing a home equity line of credit in 2nd lien position do we still need to wait the 3 days before we can close for the borrower to review the appraisal/In house evaluation . Thank you

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#2131201 - 05/19/17 06:48 PM Re: providing appraisal reports crc
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
1002.14—Rules on providing appraisals and other valuations.

(a) Providing appraisals and other valuations. (1) In general. 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.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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