If I am “Validating” an old appraisal, stating that we believe the latest appraisal we have in possession is still a good estimate of value and no new report should be ordered, should I give the acknowledgement form stating that they received the old appraisal or validation certificate I make up three days before closing?
And then give them a copy of the old appraisal?
You will need to give the notice of right to receive a copy of appraisals even if you don’t order a new appraisal or valuation. If you are using an existing appraisal the Reg B Commentary 1002.14(a)(1)-2 states:
Renewals. Section 1002.14(a)(1) applies when an applicant requests the renewal of an existing extension of credit and the creditor develops a new appraisal or other written valuation. Section 1002.14(a)(1) does not apply to the extent a creditor uses the appraisals and other written valuations that were previously developed in connection with the prior extension of credit to evaluate the renewal request.
If your validation/review of the appraisal is not a determination on the value of the property – it doesn’t state a value or opinion of the value – then it would not constitute a valuation and would not be considered a new valuation or appraisal.
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