Now the provision to have to give a copy of the appraisal at least 3 days before closing hasn’t taken place yet. It was first introduced with HVCC; which was renamed to Appraiser Independence Requirements. This is very important at this time if you are selling loans to the secondary market, and if you think you might ever want to sell them, but who knows how long that will be around.
I’m pretty sure that the requirement in Dodd-Frank on the 3 days before closing only applies to High-Risk Mortgages; I’m guessing that means Section 32 & 35 mortgages.
This requirement doesn’t go into effect until 1-21-2013 for Dodd-Frank.
Are there any requirements on the appraiser emailing the appraisal to the lender? I heard that some banks have been sited because the appraiser emails the appraisal un-securely. Has anyone heard anything about this?
The Gramm-Leach-Bliley Act regulates how consumer information is handled, and specifically addresses appraisals. If appraisals are ordered or received using regular unencrypted email, or even via fax machines in an open unsecured area, then GLB is being violated.