Ecoa Valuations Rule/sending valuations promptly

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  • #6761

    I have a question regarding FHA property “flips” and providing copies of the written valuation to the borrower. If we send the initial appraisal that was received to the borrower “promptly” or within 3 business days of closing, do we need to send the 2nd appraisal valuation within 3 business days prior to closing? If not, do we need to delay closing? PZ


    For first lien dwelling secured loans, you would need to provide a copy of all appraisals (including the second) three business days before consummation or promptly upon completion, whichever is earlier. Reg B does allow for a waiver on on these timing requirements and permits the appraisal/valuation to be delivered at or before consummation (the waiver must be obtained at least three business days before consummation).

    If the transaction is an HPML the appraisal (including the second/flip appraisal) must be provided 3 business days before consummation and there is no waiver option. Depending on your situation you may have to delay closing.

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