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Appraisal Policy "3 Days Prior" a Requirement?

Answered by: 
Randy Carey
Linda Westfall

Question: 
In a recent update for an Appraisal Policy template it was stated "The applicant will be provided a copy of the appraisal report promptly upon completion at no extra cost to the borrower, and in any event no less than three days prior to the closing of the loan". Is the three days prior a requirement of regulators?
Answer: 

Answer by Linda Westfall: There is no timing requirement in the regulation.

Answer: 

Answer by Randy Carey: I think the template vendor was just trying to get ahead of the game, as the Frank Dodd Act will eventually require this on some loans, although it has not yet been reduced to a regulation:

Section 129H. Property appraisal requirements
(c) FREE COPY OF APPRAISAL.—A creditor shall provide 1 copyof each appraisal conducted in accordance with this section inconnection with a higher-risk mortgage to the applicant withoutcharge, and at least 3 days prior to the transaction closing date.

First published on BankersOnline.com 6/20/11

First published on 06/20/2011

Filed under: 
Lending
Filed under lending as: 
Appraisal
Loans

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