HVCC and HERA

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HVCC   Effective May 1, 2009

• Promotes the accuracy of appraisals by shielding them from undue influence, and ensuring that borrowers have sufficient notice of appraisal content by requiring that borrowers receive a copy of their appraisal reports no later than three days prior to the closing of their loan absent a borrowers waiver of this requirement.
• http://www.freddiemac.com/singlefamily/home_valuation.html

 HERA (Regulation Z) Effective July 30, 2009

•  Amends the Truth in Lending Act, implemented through Regulation Z.  Has a number of provisions, including the Mortgage Disclosure Improvement Act, which changes the Truth in Lending Act requirements surrounding early and final disclosures to homebuyers and addresses the timing of when fees can be changed.
• If the homebuyer is financing the property, these new regulatory and investor guidelines will impact-and could even dictate-the closing date.
• Upfront fees cannot be collected by the lender (except for a credit report fee) until the initial disclosures are received.
• The homebuyer must be provided with a copy of their appraisal a minimum of 3 business days prior to closing.
• An increase of more than .125% in the APR from the initial Truth in Lending Disclosure (TIL) requires the TIL disclosure to be revised and reissued to the homebuyer.  The homebuyer must receive a revised TIL disclosure at least 3 business days before closing, providing the homebuyer with the time required to determine if the homebuyer is comfortable with their loan choice.
• http://www.federalreserve.gov/newsevents/press/bcreg/20090508a.htm