Regulation B ECOA Regulation Z TILA Appraisal Notice

I heard somewhere that I have to provide the Reg B appraisal notice, even if I deny or the application is withdrawn. Is that really true?

Hi there, this is Jerod Moyer with Banker's Compliance Consulting. This is going to sound crazy, but believe me, this is what the answer is. The Regulation B Equal Credit Opportunity Act has an appraisal notification requirement. That notification requirement is triggered by any application that is or will be secured by a one to four family where you will be taken a first lien on that dwelling.

So if you have one of those applications, even if you deny it immediately or within three days, it really doesn't matter, or it's withdrawn or it's incomplete for that matter, the fact that you have an application and it was to be secured by a one to four family first lien on a dwelling, you are still required to send the notice that says you may order an appraisal, and if you do, they will be provided a free copy. They being the consumer.

Now I know what you're thinking, you go, "Wait a minute. They applied today, and five minutes after they applied, I said no. There's no way in the world I'm ordering appraisal. So why would I waste my time with this notice?" Because you have to. The regulation requires it. So dumb as it may sound, Regulation B says any application that is or will be secured by a one to four family dwelling first lien requires that notice no matter what. Denied, withdrawn, incomplete, it doesn't matter.