Q: Does Regulation B permit creditors to charge members a fee for photocopies of appraisals?
A: No. The Regulation B appraisal and valuations rule requires creditors to provide a free copy of home appraisals and other written valuations promptly after they’re completed, regardless of whether credit is extended, denied, incomplete, or withdrawn. The rule applies to all written valuations (not just appraisals) that creditors develop in connection with an application for a first lien on dwelling (closed or open-end loans).
Although creditors can’t charge a fee for providing a copy of the appraisal/valuation, the regulation permits them to charge applicants reasonable fees to reimburse for the cost of the actual appraisal/valuation (unless otherwise prohibited by law). You can’t increase the reimbursement amount to cover the cost of providing documentation to the consumer.
Visit CUNA’s compliance blog—“CompBlog”—at cuna.org. Email firstname.lastname@example.org with questions or ideas, and keep the conversation going with your peers on COBWEB—CUNA’s compliance listserv.
Six federal agencies published guidance last week designed to ensure all depository institutions are aware of expectations when it comes to deposit reconciliation. CUNA’s compliance explains what it means for credit unions in a recent CompBlog post.
CUNA is concerned with a report on consumer testing used by the CFPB to analyze periodic statement forms for consumers in bankruptcy, but concurs with some of its findings. The bureau issued a report in February on its study.