Revision Request

[Meandering]

Is the VA's Tidewater protocol exempt from TILA?

I believe it is

You'll have to check with an attorney for the VA

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[Meandering]

You are a vet,

Give them a call and ask them.

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[DTB]

What is allowed is for a buyer/seller/agent to ask the lender to forward sales that the buyer/seller/agent legitimately deems appropriate, along with a request for the appraiser to consider them. Simply forwarding such a request does not (by federal law) in and of itself constitute pressure.

Serious question; What does legitimately deem appropriate mean? And by what process are those sales given that status?

Did I miss the answer to this?

So I pass along an ROV. The apppaiser provides a good clear exlanation of why the sales submitted are not relevant. Life goes on. Where is the pressure? RG just does. not want to have to reply to the kind of inquiries that DF specifically allows, so he just yells “PRESSURE”.

The onus of why these sales are deemed appropriate for MY report lies well upstream of the appraiser.
I doubt most any appraiser here would have a problem addressing the sales, maybe even within the report, if there was support provided as to their appropriateness when they are submitted for consideration.

Because I told you so is not an answer, nor is I'm just passing this along.

This is a business RELATIONSHIP, do your job ( we won't get into not providing accurate contact info, sales contract, condo questionnaires etc.) and I'll do mine thank you very much.

 

[hastalavista]

I'm not sure it is based on the source document (assuming I'm referencing the correct source):


(and from the next page)



It would not appear that a VA loan is exempt. It would appear that it falls within the covered transactions (based on this version of TILA, assuming it is the most current and up-to-date).

If that is the case, and TIdewater is not considered an infringement on the appraiser's independence (which, it can be argued, would be since the appraiser is required to alert certain stakeholders that the appraised value isn't going to equal the purchase price, and therefore stakeholders are given the opportunity to provide additional information for the appraiser to consider), then a reconsideration of value, consistent with the procedure outlined in the IFR, would be judged the same: i.e., not coercion in and by itself.

But, that's my interpretation. If i'm quoting the wrong data, I hope someone will let me know.
If another determines, "Well, Tidewater is fine, but that's the only time..." so be it.
If any VA appraisers believe that a reconsideration is coercion, perhaps they should file a complaint with the CFPB if/when they are required to follow the Tidewater Protocol.

 

[Meandering]

It would not appear that a VA loan is exempt.

Best way to know is to call and ask them, instead of guessing,

Simply because a vet is a consumer, it doesn't make all consumers vets.

Verification - not guessing.

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[hastalavista]

TILA


Page



Relevant citation



So anyone who thinks the data isn't appropriate in an ROV, please file your complaints.

 

[hastalavista]

Verification - not guessing.

Let me fix this for you:

Source Citation = Verification = Not Guessing

 

[Meandering]

Seems by this article,

They get to pick and chose what is applicable, and what isn't.

http://www.dailyreportingsuite.com/...s_qualified_mortgage_rule_for_va_backed_loans

 

[Meandering]

Not REMAKE
Not CHANGE



https://www.gpo.gov/fdsys/pkg/CFR-2012-title12-vol8/pdf/CFR-2012-title12-vol8-sec1026-42.pdf

 

[Meandering]

Let me fix this for you:

Source Citation = Verification = Not Guessing

Let me fix it for you.

The VA was not included one way or the other,

Hence your guessing that by omission, it is included.

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