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#2227410 - 12/13/19 10:20 PM Re: Additional Appraisal RustyShackleford
raitchjay Online
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OK
I didn't see Randy's last post or any of your response prior to typing that. ^^^
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TRID - TILA/RESPA Integrated Disclosures Rule
#2227411 - 12/13/19 10:23 PM Re: Additional Appraisal RustyShackleford
RustyShackleford Offline
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Thanks, RJ. I'm trying to figure out how to bolster my argument over here. I don't think the LO over here will go for the "even if it was the borrower's responsibility, we have to pay for it because we shouldn't have ordered it on behalf of the borrower."

Also, does Randy's last post change your thinking or answer?

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#2227413 - 12/13/19 10:28 PM Re: Additional Appraisal RustyShackleford
rlcarey Online
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Galveston, TX
Your three days started with you got the payoff instructions in my mind. I think the horse is out of the barn. I would be hounding this appraiser for the addendum and tell him you are willing to pay an additional fee, but if you have to order an entire new appraisal from another appraiser, he has seen his last work from your bank.
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#2227414 - 12/13/19 10:30 PM Re: Additional Appraisal RustyShackleford
raitchjay Online
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OK
I'm really not sure....i think i need to know WHOSE responsibility (the lender's or the borrower's) it is deemed to be to have known these rules (since this doesn't seem like a one-off, someone SHOULD have known it seems). If it was the borrower's responsibility, i can see making the argument that the 2nd appraisal could be a valid CC (if captured within 3 business days of learning of it) based on that. If it's considered to be the lender's responsibility, then no.
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#2227415 - 12/13/19 10:34 PM Re: Additional Appraisal RustyShackleford
RustyShackleford Offline
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Thank you both. I will proceed with making a case that we cure this one (oh, they closed it too, BTW). Have a great weekend!

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#2227472 - 12/16/19 06:32 PM Re: Additional Appraisal RustyShackleford
RR Joker Offline
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The Swamp
Originally Posted by RustyShackleford
Sounds good, thank you for letting me know. My gut tells me that RD's instructions, which we received a little less than a month ago, may preclude our ability to call this a CIC. However, the fact that the appraisal was sourced before that might change that. I'm spinning on this one!


You received RD's instructions nearly a month ago? I'd say regardless of who what when or where, you missed the CC boat.
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