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#2197491 - 11/06/18 08:31 PM CD and Appraisal Review
t0dd Offline
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Can the CD and the Appraisal acknowledgement be delivered at the same time without causing an issue in the closing date?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2197492 - 11/06/18 08:39 PM Re: CD and Appraisal Review t0dd
raitchjay Online
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The appraisal acknowledgment isn't a required document, and is a bid redundant IMO on a TRID loan. That same language is basically on the CD. If the question is can the appraisal itself be delivered with the CD, then IMO, yes. That's at least 3 business days prior to the loan date (or it should be, if you're following the CD timing requirements).
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#2197494 - 11/06/18 08:47 PM Re: CD and Appraisal Review t0dd
raitchjay Online
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(That's not to say that an appraisal received weeks or months prior to the CD issuance date should be held until then to deliver. I don't think that meets the Reg. B 'promptly upon receipt' requirements.)
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#2197502 - 11/06/18 09:08 PM Re: CD and Appraisal Review t0dd
RR Joker Offline
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RR Joker
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The Swamp
I think, but may be wrong, that Todd is asking or referring to a 'receipt' acknowledgment. If so, we use an acknowledgment for pickup in person transactions and if the appraisal/eval had not already been delivered then we include both on the pick up acknowledgment. No, it doesn't present any date issues as they run simultaneously.
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#2197505 - 11/06/18 09:24 PM Re: CD and Appraisal Review t0dd
raitchjay Online
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Yeah, to me, i don't really see where a receipt acknowledgment is required or that useful on a TRID loan. The CD basically says "i have received the appraisal at least 3 business days prior to the loan date. If i have not, i should contact my loan officer."
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#2197567 - 11/07/18 03:56 PM Re: CD and Appraisal Review t0dd
John Burnett Offline
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John Burnett
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Cape Cod
Of course, there are a lot of "acknowledgment of receipt" signatures that lenders obtain in connection with consumer real estate loans that are absolutely not required by regulation (the one exception that comes to mind is the flood notice acknowledgment). But lawyers and auditors and secondary market investors all seem to demand documentation that notices and disclosures are timely received, so lenders find themselves stuck with all those signature lines. And then, in a "Catch 22," when their procedures call for a borrower's receipt acknowledgment signature, they get dinged by their auditors (and sometimes examiners) when they miss one here and there.

Is this a great business, or what?
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