Seem that I have a lot of questions today. Please bare with me....

As I understand it, appraisal disclosures are required on commercial loan if they are: Purchase money (1-4 family dwelling); Mobile Home w/land (1-4 family); Mobile Home without land ; and interim construction. They are not required for commercial real estate with improvements or agricultural real estate with improvements or land only. Please correct me if I am wrong.

Reg B Section 202.5 (a) discusses providing the notice. Our bank provides only upon request. However, I have one loan officer stating that if the customer does not pay for the appraisal, he has no right to it, therefore, he needs no notice. I think the notice still has to be given. I can understand that the customer must pay for it prior to receiving, but to me the notice still needs to be given to the customer. I am looking at a Fannie-Mae form and the Appraisal notice doesn't state anything about the customer reimbursing the bank...

I guess I am asking..."Am I understanding the requirements of the notice?" Also,"Should the notice state that reimbursement is necessary at the time the notice is given...

Thanks for the help

I agree with you that they should be getting the notice. They have the right to request a copy of the apparisal that is used in evaluating the property.

I don't think you need to put in the notice that they need to pay for it (at least we don't).

You must give the notice. Otherwise they don't know they have rights to the appraisal.

§202.5a A creditor shall mail or deliver a copy of the appraisal report promptly (generally within 30 days) after the creditor receives an applicant’s request, receives the report, or receives reimbursement from the applicant for the report, whichever is last to occur.

In reply to:

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Please bare with me....

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How about if we just "bear" with you?

Okay. Gotta get dressed again.

You crack me up!

Back to the bear facts ....

Who paid for the appraisal and how much is not the issue. Lenders love to throw that issue into the debate -- usually to justify willful non-compliance. But, the payment issue isn't part of the rule. That lender strikes out and better make the disclosure. The disclosure will keep him --- just barely -- in compliance!

I never know when to use "bare" and "bear". Neither look correct to me... But that just goes to show you what I know.......Anyway....

Thanks for the information on the appraisals.....oh and the lesson in grammer........

Fuzzy wuzzy was a bear,
Fuzzy wuzzy had no hair;
does that mean he was a bare bear?

No, I think that was Boo Boo, the bare bear. (Geeze I can't wait to get outta here today.)

Andy, I think that's Jeez, anyway!