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#2296106 - 04/18/24 06:22 PM Delivery of Appraisal and Other Valuation product
bean2 Offline
Member
Joined: Apr 2019
Posts: 92
Regarding rule 1002.14- Would like to confirm that ALL valuation types must be provided to the borrower once determined completed and no less than 3 days prior to closing. Example: Appraisal and Desktop Appraisal were ordered, both must be delivered to the borrower, correct?

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Lending Compliance
#2296145 - 04/18/24 09:14 PM Re: Delivery of Appraisal and Other Valuation product bean2
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 930
USA
Yes. The text of Reg. B states, "all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling."
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#2296153 - 04/19/24 11:58 AM Re: Delivery of Appraisal and Other Valuation product bean2
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,528
Galveston, TX
You might have to define a desktop appraisal. Did it assign its own value to the property, or did it just not challenge the value of the original appraisal or the validity of the contents?

3. Other documentation. Not all documents that discuss or restate a valuation of an applicant's property constitute a "valuation" for purposes of ยง 1002.14(b)(3). Examples of documents that discuss the valuation of the applicant's property or may reflect its value but nonetheless are not "valuations" include but are not limited to:

vi. Appraisal reviews that do not include the appraiser's estimate of the property's value or opinion of value.
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#2296154 - 04/19/24 12:02 PM Re: Delivery of Appraisal and Other Valuation product bean2
bean2 Offline
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Joined: Apr 2019
Posts: 92
Thank you. Yes the Desktop states its own value which in this case was the same as the appraised value.

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#2296229 - 04/21/24 01:16 PM Re: Delivery of Appraisal and Other Valuation product bean2
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,663
I guess I am curious as to why both a desktop appraisal and appraisal were ordered? And as Randy stated, you might need to define what you mean by the desktop appraisal and/or provide a bit more background on the specific situation. Did you order the desktop appraisal first, and then decided you needed the full appraisal? In that case, you (most likely) need to provide both copies as you have two separate appraisals from two different appraisal orders. As In Fairness stated, Reg B states that you need to provide "all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling."

All that said, if you just go ahead and provide copies of both, you won't have issues with Regulation B.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2296242 - 04/22/24 01:43 PM Re: Delivery of Appraisal and Other Valuation product bean2
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 930
USA
"Desktop appraisal" is defined by Fannie and Freddie as an appraisal without a site visit.
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Opinions are strictly my own, and have nothing to do with my employer.

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#2296455 - 04/26/24 11:48 AM Re: Delivery of Appraisal and Other Valuation product bean2
bean2 Offline
Member
Joined: Apr 2019
Posts: 92
Yes, there was no site visit, but an opinion of value is provided. Thank you

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