For an application secured by a first lien on a dwelling, the creditor has received and completed its review of the appraisal on April 2. Consummation is April 30. The applicant has not waived the copy-delivery timing requirement. May the creditor wait until the closing table to provide the appraisal copy?
Correct Answer
B) No: provide the copy promptly upon completion or three business days before consummation, whichever is earlier
B. Delivery at the closing table is too late without a valid timing waiver. The rule requires prompt delivery upon completion as well as the earlier-of comparison with the pre-consummation deadline. Holding a completed appraisal until April 30 is not justified merely because the applicant can read it before signing. Scope and exceptions: The applicant may waive timing under the rule, not the right to receive a copy. Completion involves creditor receipt and review, not simply the appraiser's report date. No exact calendar deadline is calculated without the relevant business-day facts. Source: Section 1002.14(a)(1); comments 14(a)(1)-4 and -5 — https://www.consumerfinance.gov/rules-policy/regulations/1002/14/
Why This Is the Correct Answer
B. Delivery at the closing table is too late without a valid timing waiver. The rule requires prompt delivery upon completion as well as the earlier-of comparison with the pre-consummation deadline. Holding a completed appraisal until April 30 is not justified merely because the applicant can read it before signing. Scope and exceptions: The applicant may waive timing under the rule, not the right to receive a copy. Completion involves creditor receipt and review, not simply the appraiser's report date. No exact calendar deadline is calculated without the relevant business-day facts.
Why the Other Options Are Wrong
Option A: Acceptable: delivery at consummation satisfies the rule in every case
It incorrectly treats consummation-day delivery as universally sufficient.
Option C: Acceptable, provided the borrower is given time to read it before signing
Reading time at signing does not replace timely delivery.
Option D: Too late: the copy was due within 30 days of the application being taken
Thirty days after application is not this rule's deadline.
Exam Tip
Do not hold a completed valuation until closing merely for convenience.
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