REMN Wholesale is amending its guidance on appraisal delivery waiting periods required under the ECOA valuation rule.  This information supersedes all previously issued guidance.  The specific update to REMN Wholesale policy is highlighted in yellow below.

The ECOA valuations rule, which was effective with loan applications dated on or after January 18, 2014, states that the borrower(s) must receive the appraisal(s)/valuations(s) promptly upon completion, or at least three (3) business days prior to closing.  The timing requirement varies depending on delivery method as detailed below.

As a reminder, when counting business days, Saturday is included but Sunday and Federal holidays are not, regardless of delivery method.

Emailed Appraisal Copy

If an email address is provided for the borrower the appraisal documentation will be emailed.

The three (3) business days period begins the day the appraisal(s)/valuation(s) were emailed to the borrower (timing cannot be waived on loans that are an HPML).

Example:

Loan is scheduled to close on Friday. The appraisal(s) and valuation(s) must be emailed to the borrower no later than Tuesday to be in compliance (Tuesday, Wednesday, Thursday = 3 business days prior to close).

NOTE:  The three (3) business day waiting period begins the day the appraisal/valuation was emailed to the borrower.

Mailed Appraisal Copy

If the borrower does not have an email address, or it was not provided, REMN Wholesale will mail the appraisal documentation.

The three (3) business day ECOA waiting period requirement begins three (3) business days after the appraisal(s)/valuation(s) were mailed to the borrower (timing cannot be waived on loans that are an HPML).  A total of six (6) business days prior to close is required for appraisal copies sent via USPS mail.

Example:

Loan is scheduled to close Friday. The appraisal(s) and valuation(s) must be mailed to the borrower no later than the previous Friday to be in compliance (Friday, Saturday, Monday, Tuesday, Wednesday, Thursday = 6 business days prior to close).

NOTE:  The six (6) business day waiting period begins the day the appraisal/valuation was mailed to the borrower.

As a reminder, electronic delivery of the appraisal documentation to the borrower is the preferred method to expedite the delivery process.  Brokers should provide the borrower’s email address on the Submission Form whenever possible.

The Broker Guide to Borrower Appraisal Delivery Retrieval, which details how the borrower can access and retrieve their appraisal documentation when an email address was provided, is posted on the REMN Wholesale website, at www.remnwholesale.com under “Tools”.

If you have any questions, please contact your Account Executive

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