providing appraisal reports

Posted By: crc

providing appraisal reports - 05/12/17 08:18 PM

If we reuse an appraisal/evaluation (no changes) do we still have to provide a copy for a new loan application?

thanks.
Posted By: John Burnett

Re: providing appraisal reports - 05/12/17 08:53 PM

If you are referring to the Regulation B requirement for a copy of an appraisal developed in connection with an application for credit to be secured by a first lien on a dwelling, no, because the appraisal was not developed "in connection with" the current application for credit. You already had it.

If you reviewed the appraisal and came up with a different value after adjusting to the passage of time and changes in the market for homes in your area, yes, because you developed a new valuation in connection with the current application.
Posted By: crc

Re: providing appraisal reports - 05/12/17 09:17 PM

Yes, the Reg B requirement. Thanks for your help!
Posted By: Monster

Re: providing appraisal reports - 05/15/17 11:23 AM

This post reminded me of a question I was recently presented with. Applicant withdrew loan after appraisal had been ordered. MLO immediately contacted the appraisal company to ask them to cancel the appraisal but the appraiser was on-site at that moment. He stopped where he was and charged a lower fee. The question was "do we need to provide the incomplete appraisal?" to which I responded yes... but I didn't really like the way the whole scenario went down - I would have preferred they had called the applicant to determine whether or not they wanted the discounted/incomplete appraisal or full appraisal. What would others have done in this scenario?
Posted By: rlcarey

Re: providing appraisal reports - 05/15/17 12:25 PM

An incomplete appraisal is not an appraisal - why would the bank even accept it? If you had to pay because the appraiser was already on site is one thing - why they would put pencil to paper and deliver anything to the bank really doesn't make any sense.
Posted By: Monster

Re: providing appraisal reports - 05/15/17 02:07 PM

I agree, I suppose they felt their time needed to be justified to still get the fee. Thanks Randy!
Posted By: JWills, CRCM

Re: providing appraisal reports - 05/17/17 08:03 PM

If a customer purchases a home from the lender, and the appraisal in file was done for the lender months prior to the purchase, do we provide any notices, or copies of that appraisal?
Posted By: rlcarey

Re: providing appraisal reports - 05/17/17 08:06 PM

Yes - assuming you are using it to approve their credit application.
Posted By: tuma

Re: providing appraisal reports - 05/18/17 07:36 PM

Randy - your reply appears to contradict John's original answer.
In both instances, the valuation of the property was obtained prior to the application.
Or is there a distinction that I am missing?
Posted By: rlcarey

Re: providing appraisal reports - 05/18/17 08:20 PM

It is going to be transaction specific:

2. Renewals. Section 1002.14(a)(1) applies when an applicant requests the renewal of an existing extension of credit and the creditor develops a new appraisal or other written valuation. Section 1002.14(a)(1) does not apply to the extent a creditor uses the appraisals and other written valuations that were previously developed in connection with the prior extension of credit to evaluate the renewal request.

In this case - you have a totally new borrower who would be entitled to the valuation of the property that you are using.
Posted By: Onehotidea

Re: providing appraisal reports - 05/19/17 06:42 PM

When doing a home equity line of credit in 2nd lien position do we still need to wait the 3 days before we can close for the borrower to review the appraisal/In house evaluation . Thank you
Posted By: rlcarey

Re: providing appraisal reports - 05/19/17 06:48 PM

1002.14—Rules on providing appraisals and other valuations.

(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.