On HELOC's can we use the TAV for the application only and then order a true "Evaluation" at processing once the customer shows intent?

What are you going to do with the TAV at application? Deny the application if the TAV is not high enough??

Correct, any other recommendations?

Considering that a TAV alone is no longer an acceptable evaluation method, I wouldn't think it would be permissible as an outright denial, either. We ask the borrower their opinion on their home's value at application and base out initial approval on that. That approval of course is subject to a number of things, including an appraisal.

I agree, taking action on a TAV might also lead to some fair lending issues as you are basing your determination on a relative unknown. I would go based on what lnh0104 indicated - a statement of value by the applicant.

once we proceed with the process and order the "evaluation" and the value comes back less then expected, can the customer request for a "full blown" appraisal to find value?

I would think that would be up to your bank's policy. Personally, I would advise against it, and would trust that our evaluation methods were in line with true market values. I think in the end a lot of your borrowers may be out more money for similar results. I don't think you would be violating any regulations by allowing it, but I urge you to proceed with caution in those instances.

So to pick back up on this thread and take it a step further, what if the customers' stated value isn't sufficient to cover the loan - would you decline the loan based on the information the client gave you? I would think you could but mightn't that also be considered a bit arbitrary?

If we are discussing loan products and general guidelines prior to application and it is clear that they exceed max LTV guidelines, I would not submit an application.

You just took adverse action and turned the inquiry into an application and would have to follow the notice requirements of 202.9 regardless if you submitted a "written" application.

I agree, to an extent. If my customer comes in and asks if we do 100% financing and I say no, I do not believe I just denied an application.