Q. Does Regulation B require a credit union to provide copies of multiple versions of the same appraisal, or just the final version received?
A. The credit union only has to provide a copy of the latest version received. Regulation B Section 1002.14 (a)(1) requires a creditor to provide an applicant a copy of “all appraisals and other written valuations developed in connection with an application for credit that is to be secured by a first lien on a dwelling.” But “all” appraisals and valuations doesn’t refer to all versions of the same appraisal/valuation. If multiple versions of an appraisal or other written valuation exist, the credit union must provide only a copy of the latest version received. – Regulation B Official Staff Interpretations, Comment 1002.14-7.
Q. Are credit unions required to provide any subsequent notice of a member’s right to opt-in or revoke an opt-in after satisfying Reg E’s overdraft notice requirements for ATM and one-time debit card transactions?
A. No subsequent notice requirement exists under Section 1005.17 Regulation E.
To comply with the Reg E opt-in requirement for ATM and onetime debit card overdrafts, a credit union must:
The credit union must complete all four steps to charge the member fees for paying (or declining) ATM and onetime debit card overdrafts.
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