October 22, 2013 at 11:02 pm EDT
#4084
rcooper
Member
IMO, you would not be required to provide a copy an appraisal in the situation you described. The ECOA appraisal rule pertains to valuations in connection with an application. And both the ECOA valuation rule and Reg Z HPML rule refer to “consummation” of the transaction in the timing requirements.