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#2171887 - 04/04/18 06:05 PM Property Value - RE is " Abundance of Caution"
Libby M. Offline
Platinum Poster
Joined: Sep 2007
Posts: 604
Mississippi, USA
We have a loan that will be fully secured by a Certificate of Deposit. The lender is also taking a lien on the customer's primary residence as an "Abundance of Caution". In this case, what do we put for the Property Value on the LE and CD since an appraisal / evaluation is not required for an "Abundance of Caution."
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Lela Purvis, CRCM/CCBCO/CBAP


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TRID - TILA/RESPA Integrated Disclosures Rule
#2171892 - 04/04/18 06:15 PM Re: Property Value - RE is " Abundance of Caution" Libby M.
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Whatever you estimate it at.
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2171898 - 04/04/18 06:27 PM Re: Property Value - RE is " Abundance of Caution" Libby M.
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
This use to be a common occurrence in order to make the interest tax deductible, but with the new tax law and depending on what the funds are going to be used for, likely this was a waste of time on both the bank and customer's part. Why would a bank agree to or feel a need to do this on a fully secured CD loan??
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2172042 - 04/05/18 02:07 PM Re: Property Value - RE is " Abundance of Caution" Libby M.
Compliance NABW Offline
Diamond Poster
Joined: Oct 2015
Posts: 1,669
Ditto. The only thing the Abundance of Caution exempts you from is the Appraisal Rule. It still requires you to abide by TRID, Flood, ATR, RoR, etc. It's not worth it from a Compliance standpoint if the collateral is really just an AOC.

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