A quality-control review finds valuations reaching applicants an average of eleven days after completion, with several arriving one business day before consummation. What does the review establish?
Correct Answer
D) Provide valuation copies promptly or three business days before closing
Why this is correct: The governing concept is Regulation B (the governing federal rule, which implements the Equal Credit Opportunity Act (ECOA). For covered first-lien dwelling-secured mortgage applications, the creditor must provide the applicant a copy of all appraisals and other written valuations promptly upon completion, or no later than three business days before closing, whichever is earlier. This is a mandatory compliance requirement, not optional. Why the other choices are wrong: "Treat the compliance requirement as optional because closing is near" is wrong because Regulation B's timing rule is a strict legal requirement, not a suggestion that can be ignored based on proximity to closing. "Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue" is wrong because failing to provide the valuation copy is a specific disclosure violation that must be corrected; the rule does not allow proceeding with an unresolved violation. "Ignore the issue if the borrower orally agrees to continue" is wrong because the requirement to provide the copy is statutory; a borrower's oral agreement cannot waive this federal right. Exam tip: Remember the "promptly or three days before closing" timing rule for first-lien appraisal copies under ECOA/Regulation B. It's a key consumer protection.
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 A: Treat the compliance requirement as optional because closing is near.
Treat the compliance requirement as optional because closing is near. is not correct because the governing rule requires the compliant answer shown in the explanation.
Option B: Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue.
Continue processing without correcting the disclosure, licensing, compensation, or consumer-protection issue. is not correct because the governing rule requires the compliant answer shown in the explanation.
Option C: Ignore the issue if the borrower orally agrees to continue.
Ignore the issue if the borrower orally agrees to continue. is not correct because the governing rule requires the compliant answer shown in 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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