If we cancel a file within 3 days of application and therefore do not issue early disclosures do we still need to issue the appraisal disclosure separately? Did this change at all with TRID since the appraisal disclosure is now on the LE?
You are correct. The appraisal notice under Regulation B would still need to be given for transaction secured by a first lien on a dwell even if the loan is denied within 3 business days of application and no LE is provided.
Also keep in mind that there is an appraisal delivery notice under Reg Z related to applications for HPMLs.