In a document-cure review, a compliance analyst sees facts tied to ECOA Spousal Information Requirements. What should the file reflect?

Correct Answer

A) Provide appraisal and valuation copies on time

Why this is correct: The Equal Credit Opportunity Act (ECOA) and its implementing Regulation B have specific requirements for providing copies of appraisals and other valuations. A core rule is that these copies must be provided promptly, typically within 30 days of application or 3 business days before closing, whichever is earlier. In a document-cure review, the file must demonstrate that the lender complied with this federal timing rule for providing these documents. The correct choice directly states this required action. Why the other choices are wrong: The choice to "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because a lender's internal policy cannot override or serve as a substitute for a mandatory federal requirement. The choice to "Wait until a regulator asks for the file before applying the federal requirement" is wrong because compliance with ECOA is required at the time of the transaction, not retroactively upon regulatory inquiry. The choice to "Use prior closing disclosure approval as a substitute for the current ECOA Spousal Information Requirements requirement" is wrong because approval of a Closing Disclosure under TRID/Regulation Z is a separate requirement and does not fulfill the specific, independent obligation to provide appraisal copies under ECOA/Regulation B. Exam tip: Remember that ECOA/Regulation B's appraisal delivery rule is a strict timing requirement independent of other disclosures. 'On time' is the key phrase linking to this rule.