During intake, a first-lien appraisal is complete before closing. What is the best compliant response?
Correct Answer
A) Provide valuation copies promptly or three business days before closing
Why this is correct: Regulation B (ECOA) at 12 CFR 1002.14(a)(1) requires creditors to provide copies of appraisals and other written valuations for first-lien dwelling-secured loans. The copies must be delivered promptly or at least three business days before closing, whichever is earlier. Why the other choices are wrong: "Use an internal exception instead of the required federal disclosure or timing rule" is wrong because internal policies cannot override federal Regulation B requirements. "Wait until a regulator asks for the file before applying the federal requirement" is wrong because the timing rule is proactive and must be met before closing, not upon request. "Rely on oral agreement when the rule requires documented compliance" is wrong because Regulation B requires providing actual copies of the written valuation; oral communication does not suffice. Exam tip: For first-lien dwelling loans, always provide the appraisal copy promptly or three days pre-closing—this is a strict ECOA right.
Why This Is the Correct Answer
The correct response is "Provide valuation copies promptly or three business days before closing" because Lines 42-54; 12 CFR 1002.14(a)(1).
Why the Other Options Are Wrong
Option B: Use an internal exception instead of the required federal disclosure or timing rule.
Use an internal exception instead of the required federal disclosure or timing rule. is not correct because it does not apply the rule tested by this file scenario.
Option C: Wait until a regulator asks for the file before applying the federal requirement.
Wait until a regulator asks for the file before applying the federal requirement. is not correct because it does not apply the rule tested by this file scenario.
Option D: Rely on oral agreement when the rule requires documented compliance.
Rely on oral agreement when the rule requires documented compliance. is not correct because it does not apply the rule tested by this file scenario.
Memory Technique
ECOA and Regulation B: identify the rule being tested, then choose the action that documents or applies that rule before the file moves forward.
Exam Tip
Match the file facts to ECOA and Regulation B; do not choose an exception or shortcut that skips the required rule.
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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