I agree with Kimo. In fact, the preamble to the final rule says this:
"Consistent with the purpose of ECOA section 701(e) and ECOA more broadly, if an AVM develops a valuation in connection with the application that is provided to the creditor, then the creditor has a duty under the final rule to disclose a copy to the applicant."
While you might be able to debate whether the valuation is "complete," I wouldn't want to have that argument with an examiner if I could avoid it.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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