If there are joint borrowers, does a bank comply with Regulation B if they deliver the appraisal to one of the borrowers versus both 3 days prior to closing?
It is a best practice to send to both of the borrowers, but it is not necessarily required under Reg. B.
As long as one (the primary) applicant is sent the appraisal three days prior to closing you will meet the requirements under the Reg. The official interpretations to 12 CFR §1002.14(a) provide guidance:
"14(a) Providing appraisals and other valuations.
1. Multiple applicants. If there is more than one applicant, the written disclosure about written appraisals, and the copies of appraisals and other written valuations, need only be given to one applicant. However, these materials must be given to the primary applicant where one is readily apparent. Similarly, if there is more than one applicant for credit in the transaction, one applicant may provide a waiver under §1002.14(a)(1), but it must be the primary applicant where one is readily apparent."
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