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e-Disclosure of Appraisal

Question: 
Under TRID rules the bank must send a copy of the appraisal three days prior to closing the mortgage loan. If the appraisal is sent electronically but the customer has not opened the email, has the bank met the regulatory requirements?
Answer: 

by Dan Persfull:

If they have not acknowledged receipt of the appraisal then electronic delivery is the same as snail mail (assuming they have provided E-consent). The disclosure is assumed received 3 business days after delivery and then 3 business days after receipt before the loan can close.

Answer: 

by Randy Carey:

Just a note, it is not required by TRID and for requirements for the electronic delivery of appraisals, they should refer to Regulation B 1002.14(a)(5).

First published on 01/15/2023

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