Under the new HOEPA, HERA and HVCC Acts of Congress (explanation of acronyms not necessary here) , a homeowner must receive a copy of their appraisal at least 3 business days before the closing. So, how do they count thy days?

 

• The lender snail mails the appraisal to the borrower at their current mailing address
• US postal service should deliver this in three business days (assume it is not Christmas or Mother’s Day)
• Begin counting the day after the mail is picked up- not the day it is mailed
• Saturdays count, Sundays and holidays do not
• Appraisal should be there on the third day
• This is the day it is received
• Borrower has three days to check it out
• Can close three days after it is received by the borrower

 Problems:

• Counting on the bank to remember to mail it
• Counting on the Postal Service to deliver it on time
• If it is not received cannot close
• Might lose rate lock
• Might have to cancel the movers!

Solve problem:

•  Create a form the borrower may sign to waive the right to receive the appraisal. Spend millions creating a system and spend five minutes figuring out how to get around it.

 

Done!

Dale Siegel