Forum Replies Created
-
Posts
-
Can they email us to give us permission? I don’t think we would have to have an e-sign disclosure since we are not providing disclosures.
Does the rule not state that it the notice is required when (a)(1) applies. Since the loan has been denied and we know that (a)(1) does not apply since an appraisal or evaluation will not be ordered should the disclosure requirement not apply as well? It seems this would be confusing to the customer to be denied and then receive a notice stating that we may order an appraisal. Even though the notice says may it is not accurate since there is no possibility that we will and using may implies a possibility.
(a) Providing appraisals and other valuations. (1) In general. A creditor shall provide an applicant a copy of all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling. (2) Disclosure. For applications subject to paragraph (a)(1) of this section, a creditor shall mail or deliver to an applicant, not later than the third business day after the creditor receives an application for credit that is to be secured by a first lien on a dwelling, a notice in writing of the applicant’s right to receive a copy of all written appraisals developed in connection with the application.
If the loan is going from open end to closed end then it is a refinance under TIL even if it is done as a modification.
Even it is not an affiliate under that definition would you not receive indirect compensation from the charge?
(B) The creditor receives no direct or indirect compensation in connection with the charge;
