Our borrower's appraisal came in lower than expected. The borrower would like to pay for a rate extension and order a new appraisal in a couple of months hoping for an increase based on sales that will take place in the near future. Can we issue a new Loan Estimate with the rate extension fee, and another appraisal fee, or should we turn down this loan and start over?
I have a question in regards to section §1002.14(a)(2) and §1002.14(a)(4) below in Reg B. Section (a)(2) below states the lender shall provide the applicant a copy of the “right to receive a copy of appraisal” disclosure within 3 business days. We have a situation where the customer withdrew their loan PRIOR to the 3rd business day. According to section (a)(4) below it ONLY references back to section (a)(1) which pertains to the actual appraisal and NOT the disclosure itself. So in instances where a loan is either withdrawn, denied or incomplete prior to the 3rd business day do we have to still send the disclosure or not?
"DISCLOSURE. For applications subject to paragraph (a)(1) of this section, a creditor shall mail or deliver to an applicant, not later than the third business day after the creditor receives an application for credit that is to be secured by a first lien on a dwelling, a notice in writing of the applicant's right to receive a copy of all written appraisals developed in connection with the application. In the case of an application for credit that is not to be secured by a first lien on a dwelling at the time of application, if the creditor later determines the credit will be secured by a first lien on a dwelling, the creditor shall mail or deliver the same notice in writing not later than the third business day after the creditor determines that the loan is to be secured by a first lien on a dwelling.
WITHDRAWN, DENIED, OR INCOMPLETE APPLICATIONS. The requirements set forth in paragraph (a)(1) of this section apply whether credit is extended or denied or if the application is incomplete or withdrawn."
An Appraisal Management Company, (AMC) is increasingly charging an additional fee of $150 and attributing its justification to the CFPB's Rural or Underserved provisions. My understanding and research does not support the AMC's claim allowing this added fee. I have spoken to others in the business and they have no experiences with such a fee, short of USDA-RD fees. Is this particular AMC correct in how it is treating these properties while citing the CFPB?
I just don’t understand how my appraiser is coming up with the cap rate he is using on an appraisal. What does he consider in his work-file to determine the cap rate used?
We have been told that an “As Is” value is required for “in-house” loans, but we have had several of our appraisers argue this requirement and say that USPAP does not require this. Is this a requirement and what do I tell my appraisers?
Is a USPAP Standard 3 Review required for all of our appraisals?
Appraisers in my markets continue to raise prices and extend due dates...do I have any other choices to consider for my clients?
I have been told the recent $500,000 threshold increase for real estate evaluations applies ONLY to commercial property. Is that correct?
My community bank is located in a designated rural county. Can I look forward to taking advantage of the EGRRCPA appraisal exemption?
I am doing a HELOC for under $250,000 as a 1st Deed. Is a full interior appraisal required or can a desk-top valuation be done?