In reviewing Jack’s Reg B procedures for appraisal rules, the section pertaining to waivers, it was stated that we would require an “affirmative written statement.” The Small Entity Compliance Guide indicated that we could accept a waiver orally or in writing. Was this just a “best practice” procedure that Jack used?
You got it exactly right. The consumer can make an oral or written request. If you decide to accept an oral request, you still need to document the request. You know that if examiners see that a copy of an appraisal is given less than three days before closing they will evidence that the consumer requested a waiver, I am working on a Appraisal Waiver form. It includes a request for a waiver – I nearby request…. It includes the customer’s name, date of request, received by and date received. Can you suggest anything else we should include?
Thanks for the great question. We are starting a brief new section in our compliance masters group called Best of the Community Forum that will review recent posts that are noteworthy. Your question makes a leading contender for the next meeting. Thanks.