Non Payment for Appraisal

Home Forums Equal Credit Opportunity Act/Regulation B Non Payment for Appraisal

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    The new Appraisal Rule to provide a copy of the appraisal/valuation applies to 1st lien dwelling secured loans, as well as withdrawn, denied, or incomplete applications. If an applicant does not pay for an appraisal or evaluation we obtain for their application, and then withdraws their application, does the rule still apply? Is the bank still required to provide the copy of the appraisal to the applicant?


    From the CFPB’s ECOA Valuation Rules Small Entity Compliance Guide, p. 16:

    You cannot charge fees for photocopying or to cover the cost of postage to mail copies of appraisals or other written valuations.

    You may charge a reasonable fee to cover the cost of developing an appraisal or other written valuation, except as otherwise provided by law. You cannot condition providing copies on payment of this fee, however. If you receive a completed valuation, you must promptly provide it to the applicants, even if they do not pay for it. To ensure payment, you can collect payment before ordering the appraisal or other written valuation, subject to restrictions for some mortgages under Regulation Z (ยง 1026.19(a)(ii)). Alternatively, if you collect payment at closing, you can also provide the copy at that time if you obtain a waiver.

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