A processor is resolving TILA Appraisal Independence during a quality-control sample. Which action best fits the rule?
Correct Answer
C) Provide valuation copies within the required timing
Why this is correct: Appraisal Independence rules (like those in the Dodd-Frank Act) prohibit coercion and require that a copy of the appraisal report be provided to the borrower promptly, typically no later than three days before closing. The correct action, "Provide valuation copies within the required timing," directly complies with this mandatory consumer disclosure requirement. Why the other choices are wrong: "Use production pressure to influence the appraiser delivery date or conclusion" is wrong because any attempt to influence an appraiser's independence or timeline is illegal coercion. "Discuss a target value with the appraiser to keep the transaction alive" is wrong because suggesting a value is direct interference with the appraiser's independent judgment. "Order a second appraisal solely because the first value was too low" is wrong; ordering a second appraisal for the purpose of influencing value is prohibited unless there is a legitimate basis for questioning the first appraisal's compliance or accuracy. Exam tip: Think "Hands Off and Hand Over"—never pressure the appraiser, and always hand over the report to the borrower on time.
Why This Is the Correct Answer
The correct response is "Provide valuation copies within the required timing" because Appraisal handling requires valuation independence and timely valuation copies.
Why the Other Options Are Wrong
Option A: Use production pressure to influence the appraiser delivery date or conclusion.
This choice is not the best answer because it applies the wrong file step for appraisal and valuation independence; the governing rule is tested by the correct option.
Option B: Discuss a target value with the appraiser to keep the transaction alive.
This choice is not the best answer because it applies the wrong file step for appraisal and valuation independence; the governing rule is tested by the correct option.
Option D: Order a second appraisal solely because the first value was too low.
This choice is a tempting shortcut, but it conflicts with appraisal and valuation independence because the file still needs the required documentation, timing, or rule-based review before the action is taken.
Memory Technique
appraisal and valuation requirements: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
For appraisal and valuation independence questions, separate the required file step from plausible sales, timing, or documentation shortcuts.
Common Mistakes to Avoid
- -Choosing an internal exception instead of the governing rule
- -Treating preliminary or informal facts as a substitute for required documentation
- -Answering from a familiar but unrelated mortgage topic
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Before closing, the team discovers that a cost changes after the Closing Disclosure has already been provided. What is the safest compliant answer?
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