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#2148620 - 10/04/17 04:32 PM Providing the appraisal prior to close
Onehotidea Offline
Junior Member
Joined: Jul 2015
Posts: 36
Minnesota
I’m working on closing a home construction loan where the customer wants to close ASAP. This is not their current primary residence. Do I still need to provide them the appraisal 3 days prior to closing the loan?? Basically if I’m closing on Friday and provide them the appraisal tomorrow morning can I still close the loan?? The CD is out. Thank you!!

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#2148632 - 10/04/17 04:41 PM Re: Providing the appraisal prior to close Onehotidea
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
You should have had them sign a waiver at least three days prior to closing:

6. Waiver. Section 1002.14(a)(1) permits the applicant to waive the timing requirement if the creditor provides the copies at or before consummation or account opening, except where otherwise prohibited by law. Except where otherwise prohibited by law, an applicant's waiver is effective under § 1002.14(a)(1) in either of the following two situations:

i. if, no later than three business days prior to consummation or account opening, the applicant provides the creditor an affirmative oral or written statement waiving the timing requirement under this rule;
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#2148795 - 10/05/17 02:37 PM Re: Providing the appraisal prior to close Onehotidea
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
also, keep in mind that appraisal rules are not limited to primary residences...they apply to commercial and consumer 1-4 first mortgage loans.
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#2148798 - 10/05/17 02:43 PM Re: Providing the appraisal prior to close Onehotidea
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
And possibly consumer subordinate liens of the loan is an HPML (Regulation Z requirement). If the loan is an HPML the 3 days cannot be waived.
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