Has anyone ever ran into an issue where one borrower has signed the appraisal waiver but the other borrower later requests a copy of the appraisal? Just wondering how business lines are dealing with that.

Thanks!

I'm a bit confused. Even if a waiver is signed, they still must receive a copy at or before the loan can close.

I've never run into the situation, but it is such a small thing to do -- just provide the copy. The regulation doesn't seem to address the question.

OP, please explain 'later requests a copy'. Is it post-closing?

I agree with Joker - the borrower must still receive the appraisal at or prior to loan closing. The only thing they are waving is the three days.

If the waiver is signed, the borrower would always receive a copy at closing. The request to receive a copy of the appraisal is received before closing occurs where one borrower is requesting a copy of the appraisal. I looked in the preamable and final rule but didn't find any guidance. Due to inconsistent guidance would you provide the appraisal and disregard the waiver? I think in some cases the LO may need to have a conversation with the borrowers.

If the borrower has changed their mind and wants it before closing, why wouldn't you give them a copy once it has been reviewed and accepted?

Comp2, it sounds like you're getting waivers signed on all your loans and then not delivering till closing. Is that your process?

Yes unfortunately, the business line process is to provide a waiver at the same time they provide the initial disclosures. We have advised that that should not be the normal practice. In regards to why don't we just provide them with a copy of the appraisal, that is what we have suggested when a borrower requests a copy after signing the waiver, however, we are also getting push back because perhaps at the time of the request it could delay the closing. If they provided the apprisal instead of relying on the waiver I don't think they would run into these types of situations but in some rural areas appraisal are not very timely and agents are setting closing dates out 30 days. However, if we don't provide the appraisal I think it will reflect negatively on us.

Your process has been discussed in the threads before as not being a good idea and may even meet with examiner disapproval. The waiver is meant to be used in situations where the appraisal is delayed, not as sop.

You can always get the waiver signed at a date after application if the appraisal is going to be delayed (your rural situation, etc).

Why would a desire to see the appraisal prior to closing (lets say it is ready 2 days prior to closing and a three day waiver was already signed)...but even 5 days prior to closing if it is in house and reviewed. There is no reason to delay closing; a borrower signed a waiver of the 3 days, you are providing earlier than closing, no violation of anything (except a questionable process).