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#2041460 - 09/30/15 02:59 PM Reg B- Appraisals
WVSportsman58 Offline
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In performing a monthly review of denied loans for Reg B I want to ensure that in regards to appraisals under section 1002.14 that the disclosures for appraisals are not necessary if the bank makes its credit decision prior to an appraisal being performed...

Is my interpretation correct?

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#2041480 - 09/30/15 03:29 PM Re: Reg B- Appraisals WVSportsman58
GuitarDude Offline
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I believe the only time the appraisal notice would not be required is if you deny the loan within 3 business days of the application, similar to Reg Z/RESPA 3-day disclosures.
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#2041524 - 09/30/15 04:50 PM Re: Reg B- Appraisals WVSportsman58
Adam F Offline
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VA
If I'm not mistaken, technically Regulation B doesn't even state that if the request is denied or withdrawn within 3 business days that an appraisal notice is not required.
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#2041527 - 09/30/15 04:51 PM Re: Reg B- Appraisals WVSportsman58
Kathleen O. Blanchard Offline

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There is no exemption.
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#2041547 - 09/30/15 05:18 PM Re: Reg B- Appraisals WVSportsman58
WVSportsman58 Offline
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So to maintain proper documentation for examinations would you say it would be a good idea for a copy of the right to receive the appraisal to be maintained with the other documentation supporting the denial decision?

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#2041611 - 09/30/15 06:58 PM Re: Reg B- Appraisals WVSportsman58
Adam F Offline
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VA
That's how we handle it. Just went through an exam where the examiners went through denials extensively and they found no issues.
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It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2041823 - 10/01/15 02:08 PM Re: Reg B- Appraisals Kathleen O. Blanchard
WVSportsman58 Offline
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Kathleen B-

So even if the credit decision is made the same day the app is taken, there is still need for the right to receive a copy of the appraisal to be maintained within the denied loan documentation even if its never provided to the applicant?
Last edited by WVSportsman58; 10/01/15 02:09 PM.
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#2041864 - 10/01/15 03:27 PM Re: Reg B- Appraisals WVSportsman58
Adam F Offline
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VA
Not Kathleen, but the requirement is for the notice to be provided to the customer and there are no exemptions as Kathleen stated.

Our loan officers hand the notice to the customer with the application when they apply for a loan to be secured by a first lien on a dwelling. A copy is retained in file to prove the notice was provided.
_________________________
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2042130 - 10/02/15 02:55 PM Re: Reg B- Appraisals Adam F
WVSportsman58 Offline
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NSF-

Are you obtaining the signature on the copy of the notice when app is taken in person?

Also, for phone apps are you documenting the date is was mailed?

Thanks

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#2042148 - 10/02/15 03:25 PM Re: Reg B- Appraisals WVSportsman58
Adam F Offline
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Adam F
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VA
Yes and Yes.
_________________________
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2042154 - 10/02/15 03:32 PM Re: Reg B- Appraisals WVSportsman58
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
And I agree with this:

Not Kathleen, but the requirement is for the notice to be provided to the customer and there are no exemptions as Kathleen stated.


I don't always get back to the threads right away!
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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