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written valuations promptly after they’re completed, regardless of whether credit is extended, denied, incomplete, or withdrawn.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 email@example.com with questions or ideas, and keep the conversation going with your peers on COBWEB—CUNA’s compliance listserv.
The U.S. House will vote next week on a bill that will delay the implementation of the Consumer Financial Protection Bureau’s new mortgage rule, and create a safe harbor protecting credit unions from legal recourse through Feb. 1, 2016.