Let's say on a real estate transaction, we utilize a prior appraisal or internally-prepared evaluation. We then properly "validate" that the relied-upon appraisal/eval is still true and accurate.
How are you handling the requirement to deliver to the borrower a copy of their appraisal/eval, if you are relying on one that was pulled forward from a prior transaction, and then "validated".
Technically, no new appraisal or eval was performed. There wouldn't be a new value that was determined. And the borrower had been previously provided with a copy of the appraisal/eval from their prior transaction. Simply, the value is still "X". The was no change in value.
How are you handling this from a compliance perspective? You'd provide the borrower with the Right to Copy of Appraisal Notice within 3-days of application.... but you would not subsequently provide with a copy of an appraisal or eval, because no new appraisal/eval was performed??
And then just provide documentation in your loan file that a prior valuation was relied upon, and reference that the prior valuation was provided to the borrower on X date from the prior transaction?
Any comments from compliance examiners for this type of situation?