An appraisal on a first-lien purchase is completed on 2 June. Consummation is set for 20 June. A processor plans to hand the copy over at the closing table. What does Regulation B require instead?
Correct Answer
A) Provide valuation copies promptly or three business days before closing
Why this is correct: The proper handling is dictated by Regulation B (the governing federal rule This rule requires that for first-lien dwelling-secured loans, the creditor must provide the applicant a copy of any appraisal or written valuation promptly upon its completion, or at least three business days before consummation (closing), whichever is earlier. This action ensures compliance with federal consumer protection law. Why the other choices are wrong: "Assume licensing and NMLS authority is outside compliance review because no fee has been charged yet" is wrong because the question is specifically about appraisal disclosure under Regulation B, which is unrelated to licensing authority or fee timing. "Close or renew first and decide later whether the rule applied" is wrong because the rule clearly applies to first-lien dwelling loans, and compliance must be verified before closing; you cannot close first and assess compliance later. "Allow activity to continue while the applicable status problem remains unresolved" is wrong because the identified problem (failure to provide the appraisal copy) is a clear violation that must be resolved before proceeding; continuing with an unresolved violation is non-compliant. Exam tip: For first-lien appraisals, the rule is "provide copies promptly or three days before closing." This is a non-negotiable step in the process.
Why This Is the Correct Answer
The correct response is "Provide valuation copies promptly or three business days before closing". Regulation B requires timely copies of appraisals and written valuations for covered first-lien dwelling applications.
Why the Other Options Are Wrong
Option B: Assume licensing and NMLS authority is outside compliance review because no fee has been charged yet.
Assume licensing and NMLS authority is outside compliance review because no fee has been charged yet. is not correct because it bypasses the rule supported by the explanation.
Option C: Close or renew first and decide later whether the rule applied.
Close or renew first and decide later whether the rule applied. is not correct because it bypasses the rule supported by the explanation.
Option D: Allow activity to continue while the applicable status problem remains unresolved.
Allow activity to continue while the applicable status problem remains unresolved. is not correct because it bypasses the rule supported by the explanation.
Memory Technique
Appraisal copy timing: promptly upon completion or three business days before closing.
Exam Tip
Appraisal copy timing: promptly upon completion or three business days before closing.
Common Mistakes to Avoid
- -The applicant request is not the trigger for the copy obligation in covered applications.
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