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Reply To: Reg B Appraisal Rules

#3638
rcooper
Member

Yes, the rule covers applications for closed-end or open-end credit secured by a first lien on a dwelling. And you are correct on the timing. However, delivery occurs three business days after you mail or transmit the copies, or whenever you have evidence indicating that the applicant received the copies. The Small Entity Compliance Guide (SECG) answers a lot of questions: https://files.consumerfinance.gov/f/201305_compliance-guide_ecoa-appraisals-rule.pdf. See page 8-10 for what loans are covered and delivery information begins on page 13.

Below is an excerpt from the CFPB’s SECG:

When processing an application for a closed-end loan, you must deliver copies of appraisals and other written valuations “promptly upon completion,” or three business days before consummation, whichever is earlier. For example, if a loan will close on Friday, April 4, you must deliver the valuation no later than Tuesday, April 1. When processing an application for an open-end loan, you must deliver copies of appraisals and other written valuations “promptly upon completion,” or three business days before account opening, whichever is earlier.