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Just to add to this. We had the same question so I contacted the CFPB and they agreed that if there were 1-4 dwellings, even if there was retail space, then the ECOA valuation rules apply.
That is what I was afraid of. It is bad enough that we get all the repetative disputes from E-Oscar thinking that if we don’t respond that the negative item will fall off, but I see this as the next way to keep negative items from showing on the CBR. Not to mention that if they apply for a loan during that time that the report really won’t show the accurate information. Maybe just another unintended consequence.
Yes, I was referring to the new requirements. Since we have already covered this and I didn’t hear this addressed, does this notice need to be given if we deny the application within 3 days? Of course logically (I know not to use logic as a tool) this notice would not be needed because normally within 3 days you won’t have an appraisal or statement of value to be able to give the applicant. But I would prefer if the regulation said we didn’t have to give it if denied within 3 days. Thanks
