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CFPB Opinion on Appraisal Rule

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  • #5735
    rcooper
    Member

    We really appreciated this information we received from a member:

    The situation was this – Applicant applied for a loan and received ECOA Appraisal Notice; bank pulled an appraisal but denied the loan based on LTV; copy of appraisal was provided. ECOA compliance was satisfied with the first application. Subsequently, applicant re-applied for a lesser amount. Same appraisal as denied loan was used. Question was whether new Appraisal Notice and provision of appraisal was warranted. CFPB response was that notice was required because it attaches to the application. However, because a copy of the appraisal was already provided, the bank did not have to provide a second copy of the appraisal itself. Just FYI.

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