We have an auditor saying a loan is now a non-QM loan because the bank did not give the borrower a copy of the appraisal in a timely manner. The appraisl was mailed to the borrower but the bank did not wait 6 days until closing.

What are the ramifications of not providing an appraisal in a timely manner? Do QM rules and appraisal rules mix?

TIA

Ask them for a citation to support that claim. It is a new one on me.

Last I checked the QM and appraisal delivery requirements were not even in the same regulation.

Please let us know what their response is too.
Like Randy said, these two aren't even in the same Reg so I'm curious as to how they tie them together.
(*curious = worried my examiner might have a similar bent)

The only relationship i know of between QMs and appraisal requirements is the exemption from getting a certified appraisal on an HPML (assuming the loan is below the applicable monetary threshold) (or a 2nd, flip appraisal) for loans that are QMs.