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Waiving the borrowers’ right to receive an appraisal

Glin Castle    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

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