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Reg B: Allowed to Email Copy of Appraisal?

Question: 
Reg B - appraisals - can we email a copy of the appraisal to the Borrowers as long as it is secured and we get a read receipt for the email? How long after this do we need to wait to close the loan?
Answer: 

by Richard Insley: Section 1002.14(a)(5) of Reg. B permits you to deliver copies of appraisals electronically, provided you have first obtained the borrower's consent in the manner prescribed by ESIGN. Delivery in this fashion is the legal equivalent of placing a paper copy in the U. S. Mail.

Answer: 

by Jim Bedsole: To answer your timing question, the appraisal needs to be delivered promptly upon completion, but at least three business days prior to consummation. The three business days can be waived in writing by the borrower for a non-HPML loan, but the waiver would need to be executed at least three business days before consummation. You don't need to get or track for a read receipt for the email. Assuming you have properly complied with E-SIGN as Richard mentioned, the date the emailed appraisal was sent counts as the delivery date.

Answer: 

Editor's note: As noted, consent under the E-SIGN Act is required, regardless of who the applicant/borrower is. For consumer applicants, E-SIGN requires you to provide the consumer with information about electronic delivery, a "test drive" by the consumer, and demonstrable consent from the consumer. When the applicant is not a consumer, E-SIGN compliance consists of agreement by the applicant to receive the disclosure (or other documents) electronically. —JSB

First published on 05/12/2014

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