HomeBridge is providing additional guidance regarding the new ECOA Valuations Rule. The information below contains new information in addition to what was previously communicated in HomeBridge Bulletin 14-03, issued January 9, 2014.
The ECOA Valuations Rule requires the following:
• The borrower(s) must be notified within three (3) days of application of their right to receive a copy of the appraisal(s) or any other written valuation of the property (i.e. AVM, field review, desk review, second appraisal, and recertification of value).
• The borrower(s) must receive the appraisal(s)/valuations(s) promptly upon completion, or at least three (3) business days prior to closing. When counting business days, Saturday is included but Sunday and Federal holidays are not. The three (3) business days period begins the day the appraisal(s)/valuation(s) were either emailed or mailed to the borrower.
Example:
• Loan is scheduled to close Friday, February 10th. The appraisal(s) and valuation(s) must be either emailed or mailed to the borrower no later than Tuesday, February 7th to be in compliance.
NOTE: The three (3) business day waiting period begins the day the appraisal/valuation was emailed/mailed to the borrower.
• The copy of the appraisal(s)/ valuation(s) must be provided whether the loan is approved, denied, or withdrawn.
• The rule became effective with loan applications dated on or after January 18, 2014. HomeBridge began providing borrowers a Notice of Right to Receive Copy of Appraisal in the HomeBridge initial disclosure package effective with applications dated on or after January 10, 2014. HomeBridge began providing the appraisal/valuation copies with applications dated on or after January 18, 2014.
Notice of Right to Receive Copy of Appraisal
HomeBridge is providing a Notice of Right to Receive Copy of Appraisal (Exhibit A) in the initial disclosures mailed to the borrower(s). Brokers are encouraged to communicate the ECOA Rule to the borrower to enable the borrower to make an informed choice on whether or not to waive the timing requirement for appraisal delivery.
The Notice of Right to Receive Copy of Appraisal must be completed and signed by the borrower(s) to acknowledge receipt and included in the loan file.
The Notice of Right to Receive Copy of Appraisal has two options:
1. The borrower may elect to receive the appraisal/valuation at least three (3) days prior to close, or
2. The borrower may elect to waive the right to receive the appraisal at least three (3) days prior to close subject to specific requirements detailed under the Waiver Eligibility topic below. The borrower is waiving the timing requirement only; they are not waiving their right to receive the appraisal(s)/valuation(s) and will receive the documentation no later than closing.
Options for Delivery of Notice of Right to Receive Copy of Appraisal to HomeBridge
Option One – Include Disclosure with Loan Submission
The following is the preferred method for delivery of the Notice to HomeBridge to avoid any delays with loan closing.
• Broker provides the borrower with a copy of the Notice of Right to Receive Copy of Appraisal, by using the Notice posted on the HomeBridge website at www.homebridgewholesale.com under “Forms
