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An expertly-staffed hotline, federal regulatory tools, policies and procedures, and unlimited reviews for all sizes of community banks across the U.S. — the only all-inclusive banking compliance advisory. Compliance Hub’s over 1800 products and tools support 48 separate bank compliance areas –an unlimited-access Bank Compliance Library – and conforms to the most recently published federal banking rules and regulations. Whether you are building institutional exam-readiness or a bank compliance program, C/A has all the resources, access, and availability for one membership subscription. Co-owned by the Virginia Bankers Association and 37 other state bankers associations across the country. Contact C/A’s Membership Development Team at (888) 353-3933 or at: info@compliancealliance.com. To learn more about C/A’s new Virtual Compliance Officer service or call (833) 683-0701.

Compliance Alliance Featured Q&A

Question:

Can a lender order an appraisal prior to receiving intent to proceed under Reg Z? Is it a regulatory violation if a lender orders one without having received intent to proceed? When can we first charge for an appraisal?

Answer:

Reg Z does not expressly prohibit the actual ordering of an appraisal prior to receiving intent to proceed. However, without intent to proceed, the Bank runs the risk of not being able to charge the customer for the appraisal. Reg Z does not permit the Bank to impose most fees in connection with the transaction before the consumer has provided the intent to proceed. Once the bank has received intent to proceed, it may impose the appraisal fee. Some Banks choose not to order any appraisal prior to receiving intent to proceed because if the intent to proceed is never provided, the Bank cannot charge for it. So, this is not necessarily a regulatory error unless you attempt to charge for it without receiving intent to proceed.

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