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written valuations promptly after they’re completed, regardless of whether credit is extended, denied, incomplete, or withdrawn.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.
The new mortgage servicing rule from the CFPB clarifies the frequency of required written early intervention notices. A mortgage servicer must provide notice to a delinquent borrower no later than the 45th day of the borrower’s delinquency.
It is imperative that Congress take action to eliminate the negative consequences of last year’s changes to the Telephone Consumer Protection Act, CUNA wrote to a House subcommittee conducting a TCPA hearing Thursday.
CUNA Chief Advocacy Officer Ryan Donovan discusses this week's congressional activities, as well as advocacy strategies for the CFPB's short-term, small-dollar loan proposal in this week's Advocacy Update video.