07/29/2018
The Reg. B requirement to deliver a copy of the appraisal is limited to first lien loans. The Reg. Z appraisal requirement is for HPML loans, and QM loans are exempt. Is there any requirement to deliver a copy of the appraisal on a HELOC or a fixed rate second lien mortgage loan that is not a non-QM HPML loan?
05/20/2018
Two years ago we granted a new loan and took a first mortgage on a piece of vacant land as collateral. The loan is now going through a renewal. While completing the evaluation, we learned that the borrower; using his own cash, built a home on the property that’s encumbered. The way our mortgage reads, we have interest in ... all existing or subsequently erected or affixed buildings, improvements, and fixtures...
When we complete the valuation report, should the value of the home be included in the report and furthermore, if so, should the report be mailed to the borrower under Regulation B?
04/15/2018
When we do a renewal on commercial loan with 1-4 family as collateral we have them sign an appraisal notice - saying we have the right to do an appraisal. They might not come in to do the renewal until after maturity. Can they date this document the day they sign or do they need to back date it to the renewal date? Is this a violation if they date it after the loan renewal date?
01/14/2018
If we have a 1-4 dwelling that is being used for a commercial purpose (day care, real estate office, doctor or dentist office etc.) and our lien will be in first position, since the loan is a commercial loan do we still need to send the upfront appraisal notice? If the property is zoned commercial or granted a zoning exception does that matter?
12/24/2017
If I give the appraisal copy to every real estate loan applicant, am I still required to give the Right to Receive a Copy of the Appraisal Report notice initially?
03/26/2017
With the release of Fannie Mae's Day 1 Certainty, we are looking into allowing Property Inspection Waivers. If we exercise this option and the loan amount is over $250,000, can we prepare a written valuation to be compliant with ECOA or do we have to order a full appraisal since it is greater than $250,000? This would be in the State of Wyoming.
03/05/2017
With the release of Fannie Mae's Day 1 Certainty, we are looking into allowing Property Inspection Waivers. If we exercise this option and the loan amount is over $250,000, can we prepare a written valuation to be compliant with ECOA or do we have to order a full appraisal since it is greater than $250,000? This would be in the State of Wyoming.
11/27/2016
Can a combined counter offer/adverse action notice be issued pending
an appraisal? Model C-4 per Reg B does not allow for conditions, therefore, my interpretation is that a combined notice or counter offer can be issued only when the Bank has made its credit decision which includes determination of appraised value. Also, if appraised value is less than anticipated, the Bank may find itself in a situation where two counter-offers may need to be
provided which I don't believe is acceptable. Please advise!
11/20/2016
Can a listing agent refuse the appraiser due to past appraisals not coming in at value?
10/02/2016
We are third-party appraisers. We saw something that we have never seen before. We have a bank that is charging a customer $3000 for a commercial loan appraisal, while we were charging the bank $1800. At the very least we thought there should be some sort of disclosure that there is fee income to the bank in that pricing structure.
This is a commercial loan, not a consumer loan. We are aware that the disclosures do not apply for many items, But should not fee income to the bank, versus a actual pass-through fee be shown?