If you have a paper commercial loan application, can you put the appraisal disclosure on it to satisfy the disclosure requirement of providing it within 3 days of application? That means it would also be provided for loans that are not secured by 1-4 family dwellings - is that OK? We are struggling to provide it when applicable on commercial transactions, so I'm wondering if we can just provide it to everyone.

Don't you keep the application? How is that in a format the applicant can keep/retain then?

Get the app, mail them the disclosure. Boom.

Oh, I failed to mention it would be on the last page that the applicant could keep. My issue is some commercial folks are forgetting to provide it when secured by a 1-4 family dwelling. If they can't get it right, then maybe they should just provide it everyone.

Well, not only will that lead to certain applicants demanding a copy of an appraisal or evaluation that they may not normally be getting one (since you told them you may, and since you might, and since you now have, now they want), but it also shows a weakness in your compliance management systems by that you do not trust or have the ability in your own training and systems, that you end up over disclosing, which can also be a violation since it demonstrates that you do not understand when to or not to.

Examiners do not always see CYA decisions as particularly wise or well thought out ones.