Is anyone updating their AAN or appraisal transmittal letter in accordance with the Chase/HUD Agreement? https://www.hud.gov/sites/dfiles/FH...iation%20Agreement_Redacted_Redacted.pdf

I realize this is not a requirement but I am wondering if it is a good best practice recommendation for our lines of business or if we will lose our safe harbor on the Reg B forms if we add this information.

Thoughts?

Can you tell us your rationale for considering it? Are you currently engaging in discriminatory actions that you are trying to mitigate?

No, but we review all enforcement actions and if there are valid take aways we consider implementing them. I was just wondering if anyone was considering adding these as I think they might be helpful to consumers who are perhaps unfamiliar with their rights, but at the same time could open up a can of worms if everyone starts complaining when their value isn't what they expected.

Mostly, just trying to get an idea if other bankers are considering adding the language and what impact that might have on safe harbor.

I don't see anything that would jeopardize your safe harbor by including that language. I see little value for including that language unless you 1) are really trying to mitigate some identified flaw in your fair lending process and 2) are fully prepared to deal with customers that contact you as instructed and then be willing to turn all of that over to your regulators when asked if anyone has taken you up on it. This is an individual settlement based on discovered deficiencies.

Thank you! As you know, I very much value your opinion!!

We won't be revising the Reg. B notice since we have to provide a similar notice under state law since 2009.

Interesting, Dan. So under IN law you send a separate notice stating those things? Do you do loans in IL? If so, do you suppress the notice or just give it because it can't hurt?

We don't lend outside of the state. The notice is called the Notice to Borrower/Prospective Borrower.

https://www.in.gov/attorneygeneral/files/UPDATED_Form_HPU-01_10-1-15_edit.pdf