[tballard]

Did I miss a memo or something? Provident sent this out today. I just received this from a client. As far as I know you still cannot impose a fee on a borrower prior to receipt of the TIL. Have you heard anything?

EFFECTIVE IMMEDIATELY! **BIGGEST NEWS OF THE YEAR** EFFECTIVE IMMEDIATELY!
NO MORE WAITING ON DISCLOSURE ACKNOWLEDGEMENT…BORROWER CAN NOW-PAY FOR THE APPRAISAL BEFORE WE SEND OUT OUR DISCLOSURES!

NO TIL TO BE SIGNED, BUT – Borrower still needs to acknowledge PBM disclosures or the 4 day waiting period must pass, before the appraisal can be released to us.

OBVIOUSLY, THIS WILL SPEED THINGS UP AND HELP YOU BETTER COMPETE AGAINST NET BRANCHES AND RETAIL LO’s!!!

[rcooper]

tballard,
I apologize for not seeing your post sooner.

I’m not sure what the memo you received is talking about, but there haven’t been any changes to the prohibition on charging fees (other than credit report fee) prior to providing the early disclosures. Reg Z will be re-arranged a little on August 1, 2015 due to the integrated disclosures. I’ve linked here to BankersOnline’s copy of Reg Z showing the changing that will be effective in August 1, 2015. As you see, the prohibition on charging for appraisal before early disclosures are provided is still there and is it also in Reg X.

Reg Z, 1026.19(a)(1)(ii) and (e)(2): https://www.bankersonline.com/regs/12-1026/12-1026-019.html#19e
Reg X, 1024.7(a)(4): https://www.bankersonline.com/regs/12-1024/12-1024-007.html

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