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written valuations promptly after they’re completed, regardless of whether credit is extended, denied, incomplete, or withdrawn.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.
For credit unions, the Electronic Signatures in Global and National Commerce Act of 2000 means information required to be made available can be delivered electronically, as long as the credit union complies with its requirements.
While the DOD has affirmed the Military Lending Act’s effective date for credit card accounts of Oct. 3, CUNA is engaged with legislators to build support for efforts to exempt credit unions from the rule.