ECOA Appraisal Disclosure

Posted By: jkq1124

ECOA Appraisal Disclosure - 04/08/19 08:05 PM

In the case of an prequalification application where a property has not yet been identified (not yet a TRID application), should a separate Appraisal Disclosure be provided to the borrower within 3 days of the ECOA app date? Or would it be acceptable to send the disclosure via the LE once the property has been identified?
Posted By: rlcarey

Re: ECOA Appraisal Disclosure - 04/08/19 08:10 PM

There is no requirement that a specific property be identified, just that the loan is to be secured by a first lien on a dwelling.

1002.14(a) Providing appraisals and other valuations. (1) In general. A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling.
Posted By: jkq1124

Re: ECOA Appraisal Disclosure - 04/11/19 05:54 PM

Thanks for your feedback!

Just another thought/wrench to throw into the thought process. 1002.2(f) states: A completed application means an application in connection with which a creditor has received all the information that the creditor regularly obtains and considers in evaluating applications for the amount and type of credit requested (including, but not limited to, credit reports, any additional information requested from the applicant, and any approvals or reports by governmental agencies or other persons that are necessary to guarantee, insure, or provide security for the credit or collateral).

What if the Bank regularly obtains the property address before it considers the application received?
Posted By: rlcarey

Re: ECOA Appraisal Disclosure - 04/11/19 06:17 PM

Then it would not be a prequalification credit application request. Are you not evaluating their creditworthiness?