- Business Rules
If FIRREA allows for a real estate evaluation vs. an appraisal, do you disclose the evaluation's value as an estimated property value or as the appraised value?At the time of delivery of the Loan Estimate, "If the creditor has obtained any appraisals or valuations of the property for the application at the time the disclosure is issued to the consumer, the value determined by the appraisal or valuation to be used during underwriting for the application is disclosed as the estimated property value."
At the time of delivery of the Closing Disclosure, "Where an estimate is disclosed, rather than an appraisal, the label for the disclosure is changed to ‘‘Estimated Prop. Value.’’
Citation(s): Commentary ¶37(a)(7)-1; Commentary ¶38(a)(3)(vii)-1
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here